'The new provisions for optional statutory review apply where a direct tax appeal is sent to HMRC on or after 1 April 2009.
'The new review provisions also apply where a direct tax appeal was sent to HMRC before 1 April 2009 provided neither HMRC nor the taxpayer have taken any steps before that date to secure a hearing of the appeal by the General or Special Commissioners or the new tribunal.
'Where a direct tax appeal was sent to HMRC before 1 April...