RSTP2029 - Meaning of ‘tax position’

RSTPA guidance on the meaning of a person’s ‘tax position’.

‘Tax position’ means a person’s position at any time and any period regarding any devolved tax, including the person’s position in relation to:

  • past, present and future liability to pay any devolved tax;
  • penalties and other amounts that have been paid, or are or may be payable (by or to the person), in connection with any devolved tax; and
  • claims, elections, applications and notices that have been or may be made or given in connection with the person’s liability to pay any devolved tax.

Reference to a ‘person’ includes:

  • an individual who has died; and
  • a company that has ceased to exist.

RSTPA 2014 section 120

Ref ID


Last updated