22.—(1) A person may apply to the First-tier Tribunal for permission to appeal under section 236(2)(b) of RSTPA 2014 (late notice of review) only if—
(a)the person has approached Revenue Scotland for agreement under section 236(2)(a); and
(b)agreement has been refused or has been given only on limited grounds.
(2) Where permission to appeal may be sought under paragraph (1), the notice of review must include a request for the permission referred to in section 236(2)(b) of RSTPA 2014 and the reason why the notice of review was not provided in time.
23.—(1) The notice of appeal referred to in section 242 of RSTPA 2014 must include—
(a)the name and address of the appellant;
(b)the name and address of the appellant’s representative (if any);
(c)an address where documents for the appellant may be sent or delivered;
(d)details of the decision appealed against;
(e)the result the appellant is seeking; and
(f)the grounds for making the appeal.
(2) The appellant must provide with the notice of appeal a copy of any written record of any decision appealed against, and any statement of reasons for that decision, that the appellant has or can reasonably obtain.
(3) A person may apply to the First-tier Tribunal for permission to appeal under section 243(2)(b) of RSTPA 2014 (late notice of appeal) only if—
(a)the person has approached Revenue Scotland for agreement under section 243(2)(a); and
(b)agreement has been refused or has been given only on limited grounds.
(4) Where permission to appeal may be sought under paragraph (3)—
(a)the notice of appeal must include a request for the permission referred to in section 243(2)(b) of RSTPA 2014 and the reason why the notice of appeal was not provided in time; and
(b)unless the First-tier Tribunal gives such permission, the First-tier Tribunal must not admit the appeal.
(5) When the First-tier Tribunal receives the notice of appeal, it must give notice of the proceedings to the respondent.
24.—(1) When the First-tier Tribunal receives a notice of appeal, the First-tier Tribunal must give a direction allocating the case to one of the categories set out in paragraph (2).
(2) The categories referred to in paragraph (1) are—
(a)Default Paper cases, which will usually be disposed of without a hearing;
(b)Basic cases, which will usually be disposed of after a hearing, with minimal exchange of documents before the hearing;
(c)Standard cases, which will usually be subject to more detailed case management and be disposed of after a hearing; and
(d)Complex cases, in respect of which see paragraphs (4) and (5) below.
(3) The First-tier Tribunal may give a further direction re-allocating a case to a different category at any time, either on the application of a party or on its own initiative.
(4) The First-tier Tribunal may allocate a case as a Complex case under paragraph (1) or (3) only if the First-tier Tribunal considers that the case—
(a)will require lengthy or complex evidence or a lengthy hearing;
(b)involves a complex or important principle or issue; or
(c)involves a large financial sum.
(5) If a case is allocated as a Complex case—
(a)rule 10(1)(c) (expenses in Complex cases) applies to the case; and
(b)rule 29 (transfer of Complex cases to the Upper Tribunal) applies to the case.