Paragraph 56 The review: penalties under Schedule 24 to FA 2021
United Kingdom
If the conclusions of a review include conclusions reached by virtue of paragraph 55 and the conclusions of the review are final, sub-paragraphs (4) and (5) of paragraph 24 of Schedule 24 to FA 2021 apply but with the following modifications—
references to the appeal under paragraph 22(b) of that Schedule are to be read as references to the review required to be undertaken under paragraph 51 or 53 (as the case may be),
references to the tribunal are to be read as references to HMRC, and
references to cancelling a decision are to be read as references to concluding that HMRC’s decision is to be cancelled.
For the purposes of sub-paragraph (1), the conclusions of a review are to be treated as final only if the period specified in paragraph 57(3)(b), (4)(b) or (5) for appealing the reviewed decision has ended and no appeal has been made within that period.