I11.312A The review procedure—commencement
The internal review procedure was introduced with effect from 1 April 2009 with a view to enabling the taxpayer to reach an agreement with HMRC without the need to go to the Tribunal, thereby saving cost and expense. The taxpayer has a right to request an internal review once a notice of appeal has been given to HMRC but is not forced to go through the review procedure. The procedure is optional. If the appellant does not wish to undertake the review procedure he can notify the appeal to the Tribunal.
Once notice of appeal has been given to HMRC, the review procedure may be commenced in one of two ways. First, the appellant may notify HMRC that he requires HMRC to review the matter in question1. Alternatively, HMRC may notify the appellant of an offer to review
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