Revenue Scotland and Tax Powers Act 2014 section 243

Late notice of appeal

Section 243 explains what happens when a taxpayer misses the deadline for submitting a notice of appeal to the tribunal, and the circumstances under which a late appeal may still be accepted.

  • If the normal deadline for appealing to the tribunal has passed, a late notice of appeal can still be submitted with the agreement of Revenue Scotland or, failing that, with permission from the tribunal.
  • Revenue Scotland must agree to a late appeal if the taxpayer had a reasonable excuse for missing the deadline and made the request to appeal without unreasonable delay.
  • When a taxpayer requests that Revenue Scotland accept a late appeal, Revenue Scotland must notify the taxpayer whether or not it agrees to the request.
  • If Revenue Scotland refuses and the matter goes to the tribunal, the tribunal's decision on whether to allow the late appeal is final and cannot be further appealed.

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