Land and Buildings Transaction Tax (Scotland) Act 2013 section 42J

A payment in pursuance of a notice under paragraph 42E

Section 42J confirms that payments made to Revenue Scotland for recovery of group relief cannot be deducted for any tax purposes.

• When group relief is clawed back by Revenue Scotland, a payment notice is issued under the recovery provisions
• Any payment made in response to such a recovery notice is not tax-deductible
• The restriction applies across all taxes — the payment cannot be set against income, profits or losses for any tax purpose
• This ensures the full economic cost of the recovered relief is borne by the payer without any offsetting tax benefit