Revenue Scotland and Tax Powers Act 2014 section 152

Review or appeal against information notices

Section 152 sets out the circumstances in which a person may seek a review or appeal against an information notice issued by Revenue Scotland, including the grounds on which such a challenge may be made and the restrictions that apply.

• Where the tax tribunal has already approved a taxpayer or third party notice, or where the notice simply requires production of statutory records, the decision to issue that notice cannot be appealed.
• A challenge to a third party notice can generally only be made on the ground that compliance would be unduly onerous, unless specific provisions relating to groups of undertakings or partnerships apply.
• Notices issued to obtain information about unidentified persons can similarly only be challenged on the ground that compliance would be unduly onerous, subject to wider grounds being available in certain group or partnership situations.
• Even where wider grounds of appeal are available in group or partnership cases, a challenge cannot be made against a requirement to produce statutory records of the parent undertaking, its subsidiaries, or the partner concerned.

---