Section 49FA — Taxes Management Act 1970: Effect of conclusions of review: penalties under Schedule 24 to FA 2021

Effect of conclusions of review: penalties under Schedule 24 to FA 2021 49FA 1 If the conclusions of a review include conclusions reached by virtue of section 49EA and the conclusions of the review are final, sub-paragraphs (4) and (5) of paragraph 24 of Schedule 24 to the Finance Act 2021 apply but with the following modifications—

a references to the appeal under paragraph 22(b) of that Schedule are to be read as references to the review under section 49B or 49C (as the case may be),

b references to the tribunal are to be read as references to HMRC, and c references to cancelling a decision are to be read as references to concluding that HMRC's view is to be cancelled.

2 For the purposes of subsection (1) the conclusions of a review are to be treated as final only if the post-review period has ended and the appellant did not notify the appeal to the tribunal within that period.

3 In subsection (2) “ post-review period ” has the same meaning as in section 49G (see subsection (5) of that section).