{
  "url": "https://openlegislation.uk/finance-act-2026/schedule-21/paragraph-2",
  "json_url": "https://openlegislation.uk/finance-act-2026/schedule-21/paragraph-2.json",
  "legislation": "ukpga/2026/11",
  "legislation_title": "Finance Act 2026",
  "legislation_url": "https://openlegislation.uk/finance-act-2026",
  "path": "schedule/21/paragraph/2",
  "kind": "paragraph",
  "number": "2",
  "heading": "Offer of review",
  "text": "(1) HMRC must offer a person a review of a decision that has been notified to the person if an appeal against the decision may be brought under paragraph 1.\n(2) The offer of a review must be made by notice to the person at the same time as the decision is notified to them.\n(3) This paragraph does not apply in relation to—\n(a) a decision mentioned in paragraph 1(g) or (h) (temporary relief from suspension of registration pending review or appeal: cases other than amount of tax etc overdue), or\n(b) a decision consisting of a conclusion of a review under this Schedule.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "I",
      "label": "I1",
      "text": "Sch. 21 para. 2 in force at 14.7.2026 for specified purposes by S.I. 2026/807, reg. 3"
    },
    {
      "type": "I",
      "label": "I2",
      "text": "Sch. 21 para. 2 in force at 18.8.2026 for specified purposes by S.I. 2026/807, reg. 4(1)(a) (with reg. 5)"
    }
  ],
  "outstanding_effects": [
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
      "affecting": "uksi/2026/807",
      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    }
  ],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2026/11/schedule/21/paragraph/2",
    "retrieved_at": "2026-10-29T08:42:24.914774+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}