‘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.