Revenue Note for Guidance
Section 530N provides that where a Revenue officer has reason to believe that a principal has not declared his correct liability for a period, the officer may make an assessment on the principal covering one return period or a number of consecutive periods. A principal aggrieved by an assessment has a right of appeal subject to making a return or returns for the period assessed and paying the tax, interest and any surcharge due.
(1) Where a Revenue officer has reason to believe that a principal has not made a return or has understated the tax payable on the return, the officer may make an assessment of the total amount of tax due and payable by the principal for the return period.
(2) Without prejudice to section 530F, the amount specified on the assessment is due and payable by the principal.
(3) A Revenue officer may, if necessary, amend the assessment and the provisions of Chapter 5 of Part 41A and section 1048 (including those relating to time limits) shall, with any necessary modifications, apply to the making and amending of an assessment under this section.
(4)(a) Where a Revenue office makes or amends an assessment the principal shall be notified of the total amount of tax due and payable in accordance with the assessment.
(4)(b) Where the principal who is being assessed is a registered principal, the notice of assessment or the amended assessment shall issue by electronic means.
(5)(a) A person aggrieved by an assessment or amended assessment may appeal the assessment to the Appeal Commissioners, in accordance with section 949I within 30 days.
(5)(b) A principal shall not be entitled to appeal an assessment until all returns have been filed and the tax due and payable together with any surcharges have been paid for the periods covered by the assessment.
(5)(d) Following the determination of the appeal the tax contained in an assessment or amended assessment shall be due and payable.
(6) An assessment for a return period or for any number of consecutive periods and may be issued before the end of the period to which it relates.
(7)(a) Where an assessment relates to a number of consecutive periods, a principal may not appeal until such time as either the return required for each period is submitted or a single return for the full period of the assessment is submitted. The provisions of subsection (5) with any necessary modifications shall apply.
(7)(b) Where the assessment is in relation to a number of consecutive periods, the Appeal Commissioners shall make their determination in respect of the full period assessed.
(8) The Revenue Commissioners shall make regulations regarding assessments and such regulations may include details regarding the issuing of assessments, appeals any other related matters.
Relevant Date: Finance Act 2025