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Appeals and reviews in Scotland

This article discusses appeals against decisions of Revenue Scotland in respect of devolved taxes. For a list of the devolved taxes, see A1.501. For details of appeals against decisions by HMRC in respect of non-devolved taxes, see A5.601.

The legislation makes provision for dispute resolution, ie the settlement of appeals against certain decisions of Revenue Scotland by internal review and mediation or by referral to Tribunal¹. An appellant may not appeal to the Tribunal if a review is ongoing, an enquiry is in progress, or if the appellant has entered into a settlement agreement with Revenue Scotland².

Not all Revenue Scotland decisions are appealable, and details of the types of decision by Revenue Scotland which can be appealed, and those which cannot, are set out in legislation³. Where a decision is appealable, a taxpayer has the right to request that Revenue Scotland should review it, although no steps of a review will be undertaken until the end of any existing enquiry process⁴. The