25(1)If in the case of a chargeable transaction no land transaction return is delivered by the filing date, the Inland Revenue may make a determination (a “Revenue determination”) to the best of their information and belief of the amount of tax chargeable in respect of the transaction.
(2)Notice of the determination must be served on the purchaser, stating the date on which it is issued.
(3)No Revenue determination may be made more than six years after the effective date of the transaction.