Legislation – Finance Act 2026

a decision mentioned in paragraph 1(g) or (h) (temporary relief from suspension of registration pending review or appeal: cases other than amount of tax etc overdue), or

a decision consisting of a conclusion of a review under this Schedule.

the end of the period of 30 days beginning with the date of the notice, or

any other date set out in the notice or a further notice.

there was a reasonable excuse for not accepting the offer before the period for accepting the offer had ended, and

the request has been made without unreasonable delay after the excuse has ceased to apply.

upheld,

varied, or

cancelled.

the period of 45 days beginning with the day on which HMRC received notice of the person’s acceptance of the offer to review the decision, or

such other period as the officer and the person may agree.

may not appeal to the tribunal before the beginning of the post-review period;

may appeal to the tribunal after the end of that period only if the tribunal gives permission.

may appeal to the tribunal after the end of that period only if the tribunal gives permission.

the period of 30 days beginning with the day on which notice of the conclusions of the review was issued by an officer of Revenue and Customs, or

where paragraph 6(7) applies, the period beginning with the end of the period specified in paragraph 6(6) and ending 30 days after the day on which the notification under paragraph 6(8) is issued by an officer of Revenue and Customs.

an authorised officer of Revenue and Customs decides under section 232(1) to suspend a tax adviser’s registration,

the decision is made solely on the basis that the adviser or a relevant individual of the adviser does not meet the condition in section 227(2)(a) (amount of tax etc overdue), and

state the date from which it has effect, and

in a case where the adviser’s registration has already been suspended, temporarily reinstate the adviser’s registration.

in a case where the decision to suspend the tax adviser’s registration is cancelled on a review under this Schedule, the day on which it is cancelled;

in a case where the decision to suspend the tax adviser’s registration is upheld on a review under this Schedule, the last day on which an appeal could be brought against that decision (ignoring any possibility of an appeal brought out of time with permission), unless paragraph (c) applies;

in a case where an appeal (other than an appeal brought out of time with permission) is brought in respect of the decision to suspend the tax adviser’s registration, the day on which the appeal is finally determined.

an authorised officer of Revenue and Customs decides under section 232 (suspension of registration) to suspend a tax adviser’s registration,

paragraph 9 (amount of tax etc overdue) does not apply in relation to the decision, and

the adviser has demonstrated that if the application were not approved the adviser would be unable to continue as a going concern pending the final determination of the review or appeal, and

it is appropriate in all the circumstances to approve the application.

the prospect of the review or appeal succeeding;

any alternative steps available to, and taken by, the adviser to protect their position pending the final determination of the review or appeal;

whether the adviser has acted expeditiously in accepting the offer of the review or in bringing and progressing the appeal.

state the date from which it has effect, and

in a case where the adviser’s registration has already been suspended, temporarily reinstate the adviser’s registration.

in a case where the decision to suspend the tax adviser’s registration is cancelled on a review under this Schedule, the day on which it is cancelled;

in a case where the decision to suspend the tax adviser’s registration is upheld on a review under this Schedule, the last day on which an appeal could be brought against that decision (ignoring any possibility of an appeal brought out of time with permission), unless paragraph (c) applies;

in a case where an appeal (other than an appeal brought out of time with permission) is brought in respect of the decision to suspend the tax adviser’s registration, the day on which the appeal is finally determined.