{
  "url": "https://openlegislation.uk/finance-act-2026/schedule-21/paragraph-5",
  "json_url": "https://openlegislation.uk/finance-act-2026/schedule-21/paragraph-5.json",
  "legislation": "ukpga/2026/11",
  "legislation_title": "Finance Act 2026",
  "legislation_url": "https://openlegislation.uk/finance-act-2026",
  "path": "schedule/21/paragraph/5",
  "kind": "paragraph",
  "number": "5",
  "heading": "No review after appeal to the tribunal",
  "text": "Where HMRC have offered a person a review of a decision under paragraph 2, the person may not accept the offer under paragraph 3 or 4 if they have appealed to the tribunal against the decision.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "I",
      "label": "I1",
      "text": "Sch. 21 para. 5 in force at 14.7.2026 for specified purposes by S.I. 2026/807, reg. 3"
    },
    {
      "type": "I",
      "label": "I2",
      "text": "Sch. 21 para. 5 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",
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      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
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      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
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    {
      "type": "coming into force",
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      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
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      "affecting_title": "The Finance Act 2026 (Registration of Tax Advisers) (Appointed Days and Transitional Provision) Regulations 2026"
    },
    {
      "type": "coming into force",
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      "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/5",
    "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."
}