Revenue Scotland and Tax Powers Act 2014 section 93

Completion of enquiry

Section 93 sets out how and when a Revenue Scotland enquiry into a tax return is brought to a close, what the closure notice must contain, and the taxpayer's obligation to pay any resulting tax.

  • An enquiry ends either when Revenue Scotland issues a closure notice or, if no closure notice is given, automatically after 3 years from the relevant date
  • The closure notice must either confirm that no change to the tax return is needed or set out the amendments required to reflect Revenue Scotland's conclusions
  • Where the closure notice amends the return, the taxpayer loses the right to amend the return themselves
  • Any additional tax arising from a closure notice amendment must be paid within 30 days of the notice being issued

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