Revenue Note for Guidance
The Appeal Commissioners are precluded from accepting a late appeal where the disputed tax is subject to court or sheriff proceedings until the enforcement action has concluded. Even where a late appeal is accepted after the conclusion of the enforcement action, any legal or sheriff fees paid by an appellant cannot be refunded.
(1) The Appeal Commissioners are precluded from accepting a late appeal that is subject to enforcement proceedings until the enforcement action has concluded.
(2) An appellant shall not be entitled to any legal or sheriff fees paid by an appellant where a late appeal is accepted after the conclusion of a particular enforcement action.
Relevant Date: Finance Act 2021