Revenue Scotland and Tax Powers Act 2014 section 127

Power to obtain information and documents about persons whose identity is not known

Section 127 allows a designated officer to require a person to provide information or documents for the purpose of checking the tax position of unidentified taxpayers, subject to tribunal approval.

  • A designated officer may issue a notice requiring a person to provide information or produce a document, even when the identity of the taxpayer under investigation is unknown.
  • The information or document must be reasonably required to check the tax position of an unidentified person or class of persons, and the notice must be approved by a tribunal.
  • The tribunal must be satisfied that there are reasonable grounds to believe the unidentified person or persons may have failed, or may fail, to comply with devolved tax law, and that this is likely to cause serious prejudice to tax assessment or collection.
  • The tribunal will not approve the notice if the information or document is readily available from another source, and applications for tribunal approval may be made without giving notice to the affected party.

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