Revenue Scotland and Tax Powers Act 2014 section 94

Direction to complete enquiry

Section 94 allows a taxpayer (or other relevant person) to apply to a tribunal for a direction requiring Revenue Scotland to complete its enquiry and issue a closure notice within a specified timeframe.

• The relevant person may apply to the tribunal for a direction requiring Revenue Scotland to issue a closure notice within a specified period.
• The tribunal must grant the direction unless Revenue Scotland can demonstrate reasonable grounds for needing more time.
• The burden falls on Revenue Scotland to justify any delay in completing its enquiry.
• The tribunal hearing the application may be the First-tier Tribunal or, where tribunal rules so determine, the Upper Tribunal.