PART 6Tax returns, enquiries and assessments
CHAPTER 4Revenue Scotland enquiries
Completion of enquiry
I393Completion of enquiry
1
An enquiry under section 85 is completed—
a
when a designated officer informs the relevant person by a notice (a “closure notice”) that the enquiry is complete and states the conclusions reached in the enquiry, or
b
no closure notice having been given, 3 years after the relevant date.
2
A closure notice must be given no later than 3 years after the relevant date.
3
A closure notice must either—
a
state that in the officer's opinion no amendment of the tax return is required, or
b
make the amendments of the return required to give effect to the officer's conclusions.
4
Where a closure notice is given which makes amendments of a return as mentioned in subsection (3)(b), section 83 does not apply.
5
A closure notice takes effect when it is issued.
6
The taxpayer must pay any amount, or additional amount, of tax chargeable as a result of an amendment made by a closure notice before the end of the period of 30 days beginning with the day on which the notice is given.
7
In subsections (1) and (2) “relevant date” has the same meaning as in section 85.
I1I294Direction to complete enquiry
1
The relevant person may apply to the tribunal for a direction that a closure notice is to be given within a specified period.
2
The tribunal hearing the application must give a direction unless satisfied that Revenue Scotland has reasonable grounds for not giving a closure notice within that period.
3
In this paragraph “the tribunal” means—
a
the First-tier Tribunal, or
b
where determined by or under tribunal rules, the Upper Tribunal.