Revenue Scotland and Tax Powers Act 2014 section 233

Appealable decisions

Section 233 defines which decisions made by Revenue Scotland a taxpayer can appeal against, and which decisions cannot be appealed.

• A wide range of Revenue Scotland decisions can be appealed, including decisions affecting whether someone is liable to tax, the amount of tax due, payment dates for tax, penalties and interest, and decisions to adjust for tax avoidance
• Decisions relating to information notices and investigatory powers can generally be appealed, though some restrictions apply depending on the type of notice issued
• Certain decisions are specifically excluded from appeal, including preliminary notices about proposed anti-avoidance action, Revenue Scotland determinations, and decisions to open a tax enquiry
• Scottish Ministers have the power to update the lists of appealable and non-appealable decisions by order, including adding, removing, or varying the description of decisions on either list

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