# Finance Act 2026, Paragraph 55: The review: penalties under Schedule 24 to FA 2021

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

(1) This paragraph applies if HMRC are required, by virtue of paragraph 23(1) of Schedule 24 to FA 2021, to undertake a review under paragraph 51 or 53 of a penalty decision in respect of which an appeal lies under paragraph 22(b) of that Schedule.
(2) The review may also conclude that HMRC’s decision that the person requiring the review was liable to any of the penalty points by virtue of which they were liable to the penalty in respect of which the appeal lies is to be—
(a) upheld, or
(b) cancelled.
(3) Sub-paragraph (2) applies in relation to a penalty point even if the time limit for appealing against it expired before the relevant date.
(4) Sub-paragraph (2) does not apply in relation to a penalty point if—
(a) it was concluded on an earlier review required to be undertaken under paragraph 51 or 53 that HMRC’s decision that the person who required the review was liable to the penalty point was to be upheld, or
(b) HMRC's decision that the person who required the review was liable to the penalty point has been affirmed on appeal.
(5) In sub-paragraph (3) “relevant date” has the same meaning as in paragraph 54(6) (see paragraph 54(7)).

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Source: https://www.legislation.gov.uk/ukpga/2026/11/schedule/17/paragraph/55 (the official version)
Page: https://openlegislation.uk/finance-act-2026/schedule-17/paragraph-55
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.