# Finance Act 2026, Paragraph 53: Review out of time

Extent: E+W+S+N.I.

(1) This paragraph applies if—
(a) P has not accepted the offer of a review of a decision within the period mentioned in paragraph 49(3) (including as extended under paragraph 52) and makes a request to HMRC in writing for a review out of time, or
(b) a person other than P who may require a review of a decision has not done so within the period mentioned in paragraph 50(3) (including as extended under paragraph 52) and makes a request to HMRC in writing for a review out of time.
(2) An officer of Revenue and Customs must review the decision if the officer is satisfied that the person—
(a) had a reasonable excuse for not accepting the offer of a review or requiring the review within the applicable period, and
(b) made the request without unreasonable delay after the excuse had ceased to apply.
(3) But the officer must not review the decision if any person who has the right to appeal against the decision has done so before the request was made.

---
Source: https://www.legislation.gov.uk/ukpga/2026/11/schedule/17/paragraph/53 (the official version)
Page: https://openlegislation.uk/finance-act-2026/schedule-17/paragraph-53
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.