Section 54E | Review out of time ^F1

(1)This section applies if—

(a)HMRC have offered a review of a decision under section 54A and P does not accept the offer within the time allowed under section 54C(1)(b) or 54D(3); or

(b)a person who requires a review under section 54B does not notify HMRC within the time allowed under that section or section 54D(3).

(2)HMRC must review the decision under section 54C if—

(a)after the time allowed, P, or the other person, notifies HMRC in writing requesting a review out of time,

(b)HMRC are satisfied that P, or the other person, had a reasonable excuse for not accepting the offer or requiring review within the time allowed, and

(c)HMRC are satisfied that P, or the other person, made the request without unreasonable delay after the excuse had ceased to apply.

(3)HMRC shall not be required to review a decision if P, or another person, has appealed to the appeal tribunal under section 54G in respect of the decision.