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HMRC internal manual

Appeals reviews and tribunals guidance

Review of direct and indirect taxes decisions: Carrying out a review: Time limit for review

The review conclusion should be sent to the customer within 45 days of

  • the date HMRC receive the customer’s acceptance of our offer of a review, or
  • in direct tax where the customer has asked for a review, the date of the decision maker’s letter giving HMRC’s latest view of the matter in dispute
  • in indirect tax where a third party has requested a review, the date the review request is received

Where there has been a late acceptance of review by the customer, see ARTG4300, the 45 day review period begins on the date HMRC decide to undertake the review.

There may be cases where the review officer cannot complete their review within this time limit, for example where they are seeking further advice.

If so, they should try to agree an extension to this time limit with the customer and then write to the customer with their conclusions within this new, agreed time limit.

If the review officer does not complete the review within the agreed timeframe see ARTG4850.