Which tribunals hear tax appeals against Revenue Scotland decisions?

Tax appeals against Revenue Scotland decisions are heard by the Scottish Tax Tribunals. The First-tier Tax Tribunal for Scotland hears initial appeals, while the Upper Tax Tribunal for Scotland handles further appeals on points of law. These tribunals are independent of Revenue Scotland and provide taxpayers with an impartial forum to challenge tax decisions.

How does the two-tier Scottish Tax Tribunal structure work?

An appeal is first heard by the First-tier Tax Tribunal for Scotland. If either party believes there has been an error in law, the case can be escalated to the Upper Tax Tribunal for Scotland. This two-tier structure ensures tax decisions are properly scrutinised while keeping the appeals process accessible for taxpayers and their advisers.

How were the Scottish Tax Tribunals integrated into the wider Scottish Tribunals system?

The Tribunals (Scotland) Act 2014 (Ancillary Provisions) Regulations 2017 brought the Scottish Tax Tribunals fully within the unified Scottish Tribunals framework. This integration means the tax tribunals benefit from consistent procedural rules and governance arrangements shared across the entire Scottish tribunal system, ensuring standardised and fair proceedings.

What is the correct process for appealing a Revenue Scotland tax assessment?

A taxpayer should first use Revenue Scotland's own internal review process. If the dispute remains unresolved, an appeal can be lodged with the First-tier Tax Tribunal for Scotland. If the tribunal's decision contains an error of law, a further appeal may be made to the Upper Tax Tribunal for Scotland.

Revenue Scotland and Tax Powers Act 2014 Schedule 2 paragraph 5

The Scottish Tax Tribunals

Schedule 2 paragraph 5 establishes which tribunals handle tax appeals in Scotland and confirms how the tribunal system applies to Revenue Scotland tax disputes.

Tax appeals in Scotland are heard by the Scottish Tax Tribunals, which form part of the wider Scottish Tribunals structure established under the Tribunals (Scotland) Act 2014.
The First-tier Tax Tribunal for Scotland hears initial appeals, with the Upper Tax Tribunal for Scotland available for further appeals on points of law.
The 2017 Ancillary Provisions Regulations updated the tribunal framework to integrate tax tribunals into the unified Scottish Tribunals system.
The Scottish Tax Tribunals are independent of Revenue Scotland and provide taxpayers with an impartial forum to challenge tax decisions.

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