OpenLegislation

Paragraph 17

(1)

The relevant person may apply to the tribunal for a direction that a closure notice is to be given within a specified period.

(2)

The tribunal hearing the application must give a direction unless satisfied that HMRC have reasonable grounds for not giving a closure notice within that period.

(3)

In this paragraph “the tribunal” means—

(a)

the First-tier Tribunal, or

(b)

where determined by or under Tribunal Procedure Rules, the Upper Tribunal.