Modernising Revenue Scotland's tax administration framework – communications from Revenue Scotland to taxpayers: Consultation

Introduction

Context

Revenue Scotland was established in 2015 as Scotland’s independent tax authority under the Revenue Scotland and Tax Powers (Scotland) Act 2014 (RSTPA).^[1] It has responsibility for the collection and management of Land and Buildings Transaction Tax (LBTT) and Scottish Landfill Tax (SLfT). Revenue Scotland will be responsible for the future collection and management of Scottish Aggregates Tax, Air Departure Tax and the Scottish Building Safety Levy. It is a Non-Ministerial Office, which means that it operates independently of Scottish Ministers.

Section 251A of the RSTPA enables Scottish Ministers to make regulations about communications from Revenue Scotland to taxpayers.^[2] The regulation making power requires Scottish Ministers to consult publicly on any proposed changes before regulations are laid in draft before the Scottish Parliament.

Purpose

This consultation seeks views on proposed changes that would enable Revenue Scotland to use electronic communications as its default means of communicating with taxpayers. The consultation also explores the case for providing that, where a taxpayer opts out of receiving electronic communications or is “digitally excluded”^[3], Revenue Scotland can serve documents by ordinary post, with associated presumptions of receipt.

For the purposes of the consultation, “electronic communication” is intended to refer to communications transmitted by means of an electronic communications network or by other means but in an electronic form.^[4] This would include sending information through a broad range of digital means such as email, text, secure online portals, or other electronic platforms, such as the secure message service through Revenue Scotland’s Scottish Electronic Tax System (SETS). It may also include other forms of electronic communications such as social media.

To summarise, the key proposals set out in this consultation are:

1. Digital by default:

• Correspondence from Revenue Scotland to taxpayers is issued digitally by default. This includes high volume customer service letters and formal notices.
• Taxpayers could opt out if digitally excluded or they do not wish to receive digital correspondence.

2. Ordinary Post:

• Used by Revenue Scotland to communicate with taxpayers that are digitally excluded or elect to receive non-electronic communications.
• Correspondence sent by ordinary post would have a presumption of receipt by the taxpayer.

Some correspondence would continue to be sent by recorded delivery/signed for post including for example correspondence for high value cases or where court rules require this.

The proposals take account of Revenue Scotland’s operational experience since 2015, its commitment to a digital-first approach to the collection and management of the fully devolved taxes, as reflected in its current Corporate Plan,^[5] and evidence of taxpayer readiness for change.

The proposals also reflect the Scottish Government’s commitment to public service reform, the Tax Strategy^[6] and Digital Strategy for Scotland^[7], and the planned introduction of three new fully devolved taxes by April 2028. These new taxes will increase both the number and diversity of taxpayers with whom Revenue Scotland will communicate, reinforcing the need to explore opportunities to modernise and further enhance its administrative arrangements.

The overall intention of any changes would be to support and enhance Revenue Scotland’s operational efficiency and provide greater accessibility and certainty for taxpayers, whilst supporting taxpayers who choose to opt out or are otherwise digitally excluded so that they can receive communications by ordinary post.

Although this is a Scottish Government consultation it has been developed in close partnership with Revenue Scotland, and the tax authority will be involved in the process of consultation and any subsequent development of regulations.^[8]

Scope

This consultation will run for 12 weeks until 15 June 2026. Responses are encouraged from all interested stakeholders.

Responses will help to inform the Scottish Government’s further consideration of the issues raised. It will, however, be for a future administration in the next Session of the Scottish Parliament to determine whether any further action is taken on this matter, including whether legislation should be brought forward to provide for any changes.