PART 8REVIEWS AND APPEALS

CHAPTER 3APPEALS

178Making an appeal

1

An appeal against an appealable decision must be made to the tribunal.

2

But a person may not make an appeal to the tribunal if subsection (3), (4) or (5) applies.

3

This subsection applies where—

a

the decision which the person wishes to appeal against is a decision of WRA to amend the person’s tax return under section 45 while an enquiry is in progress, and

b

the enquiry has not yet been completed.

4

This subsection applies where—

a

the person has given WRA notice of a request under section 173 for a review of the decision which the person wishes to appeal against, and

b

the period within which WRA must issue notice of the conclusions of the review under section 176(5) has not yet ended.

5

This subsection applies where the person—

a

has entered into a settlement agreement in relation to the decision which the person wishes to appeal against, and

b

has not given notice of withdrawal from the agreement under section 184(4).

6

This section does not prevent an appealable decision from being dealt with in accordance with section 184.