This Part makes provision about the review and appeal of certain decisions of Revenue Scotland including—
(a)which decisions are, and which are not, reviewable and appealable,
(b)the taxpayer’s right to have decisions reviewed and the nature and conduct of those reviews,
(c)the option of mediation following a review that doesn’t settle the matter in question,
(d)the taxpayer’s right to appeal decisions to the tribunal, whether following review or otherwise, and
(e)settling tax disputes by agreement and other supplementary matters.
(1)The following decisions of Revenue Scotland are appealable decisions—
(a)a decision under section 66 to make adjustments to counteract a tax advantage,
(b)a decision in relation to the registration of any person in relation to any taxable activity,
(c)a decision which affects whether a person is chargeable to tax,
(d)a decision which affects the amount of tax to which a person is chargeable,
(e)a decision which affects the amount of tax a person is required to pay,
(f)a decision which affects the date by which any amount by way of tax, penalty or interest must be paid,
(g)a decision in relation to a penalty under the following provisions—
(i)section 76,
(ii)section 112,
(iii)section 151,
(iv)Part 8,
(v)section 231,
(vi)paragraph 5 of schedule 3,
(h)subject to subsection (2), a decision in relation to the giving of an information notice or in relation to the use of any of the other investigatory powers in Part 7,
(i)subject to subsection (3), a decision in relation to the giving of a notice under section 228.
(2)See section 152 for decisions in relation to the giving of information notices that are not appealable or are appealable only on certain grounds and in certain circumstances.
(3)See section 229 for the grounds on which decisions in relation to the giving of notices under section 228 are appealable.
(4)The following decisions of Revenue Scotland are not appealable decisions—
(a)the giving of a notice under section 68,
(b)the making of a Revenue Scotland determination,
(c)a decision to give a notice of enquiry under section 85 or paragraph 13 of schedule 3.
(5)The decisions mentioned in subsection (1) are appealable whether they are decisions under this Act or any other enactment.
(6)The Scottish Ministers may by order modify subsection (1) or (4) to—
(a)add a decision to either subsection,
(b)vary the description of a decision,
(c)remove a decision from either subsection.