530N Assessment by Revenue officer.
(1) Where, in respect of a return period, a Revenue officer has reason to believe that a principal has not made a return under section 530K or 530M or that the amount of tax due and payable by a principal under this Chapter for a return period was greater than the amount of tax, if any, specified in a return made or deemed to have been made by that principal for that return period, then, without prejudice to any other action which may be taken, the officer may make an assessment in one sum of the total amount of tax which in his or her opinion is due and payable by the principal in respect of that return period.
(2) Without prejudice to section 530F, but subject to subsection (5), the amount of tax specified in an assessment under subsection (1) shall be due and payable to the Revenue Commissioners from the person so assessed.
(3) (a) A Revenue officer may, where he or she considers it necessary, amend an assessment of tax made under subsection (1).
(b) Without prejudice to anything in this Chapter, the provisions of
>sections 955, 956 and 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, in accordance with this section, the Revenue officer makes or amends an assessment, he or she shall give notice to the person assessed showing the total amount of tax due and payable in accordance with the assessment.
(b) Where the person assessed is a registered principal, the Revenue officer shall issue the notice of assessment or of amended assessment by electronic means.
>(a) Subject to paragraph (b), where notice is given to a person under subsection (4), the person may, if he or she claims that the total amount of tax assessed is excessive, on giving notice in writing to the Revenue officer within the period of 30 days from the date of the notice, appeal to the Appeal Commissioners.<
(b) A person to whom notice is given under subsection (4), shall not be entitled to appeal to the Appeal Commissioners—
(i) in the case of a person who has made a return (including a deemed return) under section 530K or a return under section 530M, until that person has paid the tax and any surcharge due and payable on the basis of his or her return together with the related interest due under section 530Q, and
(ii) in any other case, until the person has made a return under section 530M for the return period concerned and has paid the tax and surcharge due and payable on the basis of that return together with the related interest due under section 530Q.
(c) The provisions of the Tax Acts relating to appeals shall, with any necessary modifications, apply to appeals against assessments made under this section as if those appeals were appeals against an assessment to income tax.
(d) On the determination of an appeal, the tax contained in an assessment or in an amended assessment shall, subject to section 530F, be due and payable by the person assessed to the Revenue Commissioners.
(6) A Revenue officer may make an assessment for a return period or for any number of consecutive return periods and an assessment may be issued before the end of the period to which it relates.
(7) (a) Subject to paragraph (b), where a Revenue officer makes an assessment for a number of consecutive return periods, the person to whom notice is given shall not be entitled to appeal to the Appeal Commissioners until such a time as the person—
(i) makes the return required in respect of each return period covered by the assessment, or
(ii) elects to make one return covering the full period assessed and makes that return,
and subsection (5) shall apply with any necessary modifications.
(b) Where paragraph (a)(ii) applies,
>a hearing of the Appeal Commissioners shall be< in respect of the full period assessed.
(8) The Revenue Commissioners shall make regulations for the purposes of this section and such regulations may provide for—
(a) the issuing of notices of assessment or amended assessment including the means by which such notices shall be issued,
(b) the transmission of information in connection with appeals,
(c) the format and transmission of returns in connection with appeals,
(d) the procedures to apply to give effect to subsection (7), and
(e) any other related matters.