Appealing a Revenue Scotland decision
Produced in partnership with Kenneth Campbell QC of Sheriff Court Bench of Scotland
Appealing a Revenue Scotland decision

The following Tax practice note produced in partnership with Kenneth Campbell QC of Sheriff Court Bench of Scotland provides comprehensive and up to date legal information covering:

  • Appealing a Revenue Scotland decision
  • Decisions and the right of appeal
  • Right of appeal
  • Appealable decisions
  • Non-appealable decisions
  • Review of its own decisions by Revenue Scotland
  • When a review cannot be requested
  • Contents of notice of review
  • Time limit for requesting a review
  • Duty and nature of Revenue Scotland’s review
  • More...

Appealing a Revenue Scotland decision

Coronavirus (COVID-19) impact on tribunals: For information on the coronavirus implications for appeals to, and hearings at, the Scottish tax tribunals, see Practice Notes: Coronavirus (COVID-19)—tax implications—Tax tribunals and Coronavirus (COVID-19)—Scotland tracker—Courts and Tribunals.

This Practice Note outlines the procedure for appealing a decision made by Revenue Scotland in relation to any of the Scottish devolved taxes. Where relevant, it also compares the Scottish procedure to the procedure for appeals against a decision by HMRC in the UK tribunals (the UK procedure is explained in further detail in Practice Note: Appealing an HMRC decision.

It is important to note that there are time limits at all stages of the appeal process, so failing to adhere to a time limit may mean that the right of appeal is lost.

For an introduction to the Scottish tax tribunal system, which deals with appeals in devolved tax matters in Scotland, see Practice Note: Scotland: devolved taxes and the Scottish tribunal system.

For ease of reference, this Practice Note refers to:

  1. the First-tier Tribunal for Scotland (Tax Chamber) as the Scottish FTT

  2. the Upper Tribunal for Scotland as the Scottish UT

  3. the First-tier Tribunal (Tax Chamber) as the UK FTT

  4. the Upper Tribunal (Tax and Chancery Chamber) as the UK UT

  5. the First-tier Tribunal for Scotland Tax Chamber (Procedure) Regulations 2017, SSI 2017/69 as the Scottish FTT Rules,

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