If, in the case of import VAT, HMRC give a person or his representative a notice informing him:

(1)that they have decided that the person has engaged in conduct by which he contravenes a relevant rule; and

(2)that the person is, in consequence, liable to a penalty; but

(3)that they do not intend to issue a demand notice in respect of the penalty,

the person or his representative may give a notice to HMRC requiring them to review the decision mentioned at (1) above (FA 2003, s. 33(1)).

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