Value Added Tax Act 1994 section 83E

Review out of time

Section 83E allows a person who has missed the deadline to accept or request an HMRC review of a VAT decision to apply for a late review, provided they can demonstrate a reasonable excuse for the delay.

  • Where a person misses the deadline to accept HMRC's offer of a review, or misses the deadline to request a review themselves, they may still apply for a late review by writing to HMRC
  • HMRC must carry out the review if satisfied that the person had a reasonable excuse for missing the original deadline
  • The person must also have made their late request without unreasonable delay once the excuse no longer applied
  • No late review is available if the person has already appealed the decision to the tribunal

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