Taxes Management Act 1970 section 49E

Nature of review etc.

Section 49E sets out the rules governing how HMRC must conduct a review of a disputed tax matter, including the scope of the review, the time limits for completing it, and what happens if HMRC fail to meet those time limits.

• HMRC determine the nature and extent of the review, but must have regard to steps already taken to decide or resolve the matter before the review began.
• The review must take account of any representations made by the appellant, provided they are made early enough for HMRC to consider them properly.
• The review may conclude that HMRC's original view is upheld, varied, or cancelled, and HMRC must notify the appellant of the conclusions and reasoning within 45 days of the relevant day (or such other period as is agreed).
• If HMRC fail to notify their conclusions within the required time period, the review is automatically treated as having upheld HMRC's original view, and HMRC must notify the appellant of that deemed conclusion.