Paragraph 14
(1)
A determination under paragraph 11 is binding on the parties to the referral in the same way, and to the same extent, as a decision on a preliminary issue in an appeal.
(2)
The officer of Revenue and Customs conducting the enquiry must take the determination into account—
(a)
in reaching conclusions on the enquiry, and
(b)
in the formulation of any amendments of the return that may be required to give effect to those conclusions.
(3)
The question determined may not be reopened on an appeal, except to the extent that it could be reopened if it had been determined as a preliminary issue in that appeal.