Section 33D | Review out of time ^F1

(1)This section applies if—

(a)HMRC have offered a review of a decision under section 33A, and

(b)P does not accept the offer within the time allowed under section 33B(1)(b) or 33C(2).

(2)HMRC must review the decision under section 33B if—

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

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

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

(3)HMRC shall not review a decision if P has appealed to the appeal tribunal under section 33F in respect of the decision.