Revenue Scotland and Tax Powers Act 2014 section 239

Notification of conclusions of review

Section 239 sets out the time limits within which Revenue Scotland must notify a taxpayer of the outcome of a review, and the consequences if Revenue Scotland fails to meet that deadline.

• Revenue Scotland must notify the appellant of the review conclusions and its reasoning within 45 days of informing the appellant of its view of the matter, or within a different period if both parties agree
• The 45-day clock starts on the date Revenue Scotland notified the appellant of its view of the matter under review
• If Revenue Scotland fails to notify the appellant of the conclusions within the required period, the review is automatically treated as having upheld Revenue Scotland's original view
• Even where the review is deemed to have upheld the original view due to a missed deadline, Revenue Scotland must still formally notify the appellant of that deemed conclusion