959AH Chargeable persons: requirement to submit return and pay tax.
(1) Where a Revenue officer makes a Revenue assessment, no appeal lies against the assessment until such time as—
(a) where the assessment was made in default of the delivery of a return, the chargeable person delivers the return, and
(b) in all cases, the chargeable person pays or has paid an amount of tax on foot of the assessment which is not less than the tax which—
(i) is payable by reference to any self assessment included in the chargeable person’s return, or
(ii) where no self assessment is included, would be payable on foot of a self assessment if the assessment were made in all respects by reference to the statements and particulars contained in the return delivered by the chargeable person.
(2) A Revenue officer shall refuse an application for an appeal unless the requirements of both paragraph (a) and (b) of subsection (1) have been satisfied within the time for bringing an appeal against the assessment.
(3) References in subsection (1) to an amount of tax shall be construed as including any amount of interest which would be due and payable under section 1080 on that tax at the date of payment of the tax, together with any costs incurred or other amounts which may be charged or levied in pursuing the collection of the tax contained in the assessment or the assessment as amended, as the case may be.
(4) The requirements of this section apply in relation to an assessment as amended by a Revenue officer as they apply to a Revenue assessment made by a Revenue officer.