Revenue Scotland and Tax Powers Act 2014 section 66

Counteracting tax advantages

Section 66 gives Revenue Scotland the power to counteract tax advantages arising from artificial tax avoidance arrangements, and sets out how those adjustments may be made.

• Revenue Scotland may make adjustments it considers just and reasonable to counteract tax advantages from artificial avoidance arrangements
• Adjustments can apply to the tax in question or any other devolved tax, and may impose or increase a tax liability where none (or a smaller one) would otherwise exist
• Adjustments can be implemented through various mechanisms, including amending or correcting returns, making assessments or determinations, entering into contract settlements, or any other method Revenue Scotland considers appropriate
• Revenue Scotland must follow the required procedural steps before taking action, and all adjustments are subject to statutory time limits