Revenue Scotland and Tax Powers Act 2014 section 240

Effect of conclusions of review

Section 240 explains what happens once Revenue Scotland has completed a review and notified the taxpayer of its conclusions, and when those conclusions can be superseded.

  • Once Revenue Scotland notifies a taxpayer of the conclusions of a review, those conclusions are treated as a binding settlement agreement between the parties.
  • Unlike a normal settlement agreement, the taxpayer cannot withdraw from this deemed agreement — the usual 30-day withdrawal right does not apply.
  • The deemed settlement is overridden if the taxpayer and Revenue Scotland enter into mediation and reach a separate settlement agreement through that process.
  • The deemed settlement is also overridden if the taxpayer lodges a formal notice of appeal to the tax tribunal.

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