# Finance Act 2026, Paragraph 7: Bringing of appeals

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

(1) This paragraph applies where HMRC have offered to review a decision that a person may appeal against to the tribunal.
(2) The right of the person at any time to appeal to the tribunal depends on whether or not the person has accepted the offer at that time.
(3) If the person has accepted the offer, the person—
(a) may not appeal to the tribunal before the beginning of the post-review period;
(b) may appeal to the tribunal after the end of that period only if the tribunal gives permission.
(4) If the person has not accepted the offer, the person—
(a) may appeal to the tribunal within—
(i) the period of 30 days beginning with the day on which notice of the offer to review the decision was issued by HMRC, or
(ii) if the period for accepting the offer has been extended under paragraph 3(2), such extended period;
(b) may appeal to the tribunal after the end of that period only if the tribunal gives permission.
(5) In this paragraph “post-review period” means—
(a) the period of 30 days beginning with the day on which notice of the conclusions of the review was issued by an officer of Revenue and Customs, or
(b) where paragraph 6(7) applies, the period beginning with the end of the period specified in paragraph 6(6) and ending 30 days after the day on which the notification under paragraph 6(8) is issued by an officer of Revenue and Customs.

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Source: https://www.legislation.gov.uk/ukpga/2026/11/schedule/21/paragraph/7 (the official version)
Page: https://openlegislation.uk/finance-act-2026/schedule-21/paragraph-7
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.