Revenue Scotland and Tax Powers Act 2014 section 69

Final notice to taxpayer of counteraction of tax advantage

Section 69 requires the designated officer to issue a final notice to the taxpayer confirming whether a tax advantage will be counteracted under the general anti-avoidance rule, and if so, what adjustments will be made.

  • After the deadline for the taxpayer to make representations has passed, the designated officer must issue a final notice
  • The notice must state whether the tax advantage arising from the tax avoidance arrangement will be counteracted
  • If counteraction is confirmed, the notice must set out the adjustments required to give effect to it
  • Where relevant, the notice must also specify any steps the taxpayer must take, and the time allowed to complete them

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