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.