ARTG2730 - Reviews and appeals for direct taxes: Settlement of appeals: Where customer does not respond
Where the decision maker has written to the customer to offer them a review and the customer
- does not reply accepting the review offer, and
- does not notify an appeal to the tribunal
within 30 days from the date of the letter offering the review, the appeal is treated as settled in line with HMRC’s view of the matter given in the review offer letter.
Where a review officer has sent a conclusion of review letter, it is treated as if it were an agreement in writing under section 54(1) TMA 1970.
Where the review officer has sent the customer a conclusion of review letter and the customer does not notify an appeal to the tribunal within 30 days of the date of that letter, the appeal is treated as settled in line with HMRC’s view of the matter given in the conclusion of review letter.
Standard template wording for use where an appeal is treated as being settled by agreement can be found in ARTG15000.