Revenue Scotland and Tax Powers Act 2014 section 103

Time limits for Revenue Scotland assessments

Section 103 sets out the time limits within which Revenue Scotland must issue tax assessments, including extended deadlines for cases involving deliberate tax loss and special rules where the taxpayer has died.

  • The standard time limit for a Revenue Scotland assessment is 5 years from the filing date (or actual submission date, if later)
  • Where tax has been lost due to deliberate action by the taxpayer or a related person, the time limit extends to 20 years
  • An assessment to recover an excessive tax repayment is still in time if made within 12 months of the repayment
  • Where a taxpayer has died, assessments on personal representatives must be made within 3 years of death, and cannot reach back more than 5 years before death

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