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HMRC internal manual

Senior Accounting Officer Guidance

Appeals: conclusion of review

The review should be completed within 45 days (or longer agreed period). The review officer should write to the person to tell them their review conclusion. For an SAO related penalty the review conclusion will be that the penalty is either

  • upheld, or
  • cancelled.

If the review officer does not send a conclusion of review letter to the customer at the end of 45 days (or an agreed longer period) they should contact the customer, by phone if possible, and negotiate an extension to the review period. They should then write to the customer and confirm the agreed extended time limit for completion of the review.

If the customer does not agree to an extension of the review period, the review officer must stop work on the review and instead write to the customer to tell them that the decision is treated as upheld, see ARTG4850.

When the person receives HMRC’s review conclusion they have 30 days in which to either

  • do nothing
  • accept the review conclusion, or
  • notify their appeal to tribunal.

If they do nothing or accept the review conclusion then the appeal is settled in line with HMRC’s review conclusion.

If they do not accept the review conclusion and wish to pursue their appeal, they must notify their appeal to the tribunal within 30 days of the review conclusion.

More information about what happens following a review is at ARTG4800+.