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HMRC internal manual

Appeals reviews and tribunals guidance

Restoration decisions: arranging for a review: late review requests

If the customer writes to HMRC and asks for a review of a restoration decision after the 45 day time limit has expired, the review officer should allow the request if

  • the customer has a reasonable excuse, see ARTG6260, for not replying within the time limit, and
  • the customer asked for a review without unreasonable delay after the excuse ended (Section 14A(3)(b) Finance Act 1994).

If the review officer decides to accept the customer’s request for a review they should write to the customer and confirm that they accept the review request outside the time limit.

If the review officer does not accept the customer’s late request for a review they should write to the customer, explaining the reasons for their decision.

The review officer should also explain that they may apply to the tribunal to order HMRC to carry out a review and provide details of theTribunals Service website for more information about this (s 14A(4) FA 1994).