Article 136 - Late Appeals

(1) An appeal may be brought out of time if on application for the purpose, the Tax Department are satisfied there was a reasonable excuse for not bringing the appeal within the time limit, and that the application was made thereafter without unreasonable delay.
(2) Where the Tax Department do not accept an application under Article 136(1) the QFC Entity whose appeal it is may apply to the Tax Department, by notice in writing, for that decision to be reviewed under Article 134 as if it were a separate appeal.
(3) If the question of whether a late appeal should be accepted or not is referred to the Regulatory Tribunal, that Tribunal may hear the question separately, or as a preliminary matter in the hearing of the appeal itself.
Amended (as from 18th June 2014)