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HMRC internal manual

Securities Guidance

HM Revenue & Customs
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Introduction and the law: the law on security: Value Added Tax: taxable person’s right to a review

Under the provisions of section 83A of the Value Added Tax Act 1994 HMRC must offer a review of the decision to require security.

83A Offer of review

(1) HMRC must offer a person (P) a review of a decision that has been notified to P if an appeal lies under section 83 in respect of the decision.

(2) The offer of the review must be made by notice given to P at the same time as the decision is notified to P.

(3) This section does not apply to the notification of the conclusions of a review.

83C Review by HMRC

(1) HMRC must review a decision if -

(a) They have offered a review of the decision under section 83A, and  

(b) P notifies HMRC accepting the offer within 30 days from the date of the document containing the notification of the offer.