Guidance on Announced and Unannounced Business Premises Inspections

Revenue Scotland inspections of business premises

Revenue Scotland can inspect business premises as part of a tax enquiry, usually by arranging the visit in advance. If a time cannot be agreed, it must normally give at least 7 days’ written notice and choose a reasonable time. Unannounced visits are only allowed where giving notice would seriously prejudice the assessment or collection of tax, and the occupier can refuse entry, although that may have further consequences.

• Most inspections are announced and Revenue Scotland will usually try to agree the date and time with the occupier or another authorised person.
• If no time is agreed, Revenue Scotland must normally give at least 7 days’ written notice, explain the possible consequences of obstruction, and mention any tribunal approval.
• For companies and other business entities, agreement or notice should be given to an appropriately senior person, such as a director, partner or site manager.
• Unannounced inspections are exceptional and require reasonable grounds to believe that advance notice would seriously prejudice the assessment or collection of tax.
• Inspections must take place at a reasonable time unless the occupier agrees otherwise, with what is reasonable depending on the type of business and its opening hours.
• At the end of the visit, Revenue Scotland should explain what happens next, such as whether it will return, send an outcome letter, or continue the enquiry in another way.

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Revenue Scotland inspections of business premises: announced and unannounced visits

This page explains how Revenue Scotland says it will carry out an inspection of business premises under its investigatory powers. The source material is about procedure rather than tax liability, but it matters because it sets the rules for when an inspection can take place, what notice should be given, and what happens if entry is refused.

What this rule is about

Revenue Scotland can inspect business premises in some tax enquiries. The official guidance says that inspections of your business premises, or the premises of an involved third party, must take place within one of two frameworks: an announced inspection or an unannounced inspection.

The guidance also recognises a separate safeguard: in some cases Revenue Scotland may apply to the tribunal for approval of an inspection. That approval does not replace the basic framework for how the inspection is carried out, but it can affect what the written notice must say.

The practical issue is straightforward. If Revenue Scotland wants to inspect premises, the occupier needs to know whether the visit is being arranged in advance, whether formal written notice is required, and what rights and obligations apply on the day.

What the official source says

The guidance says most inspections will be announced. In an announced inspection, the occupier is told before Revenue Scotland arrives. Usually Revenue Scotland will contact the business first and make sure it is dealing with the right person, or someone with authority to agree the inspection date and time.

If a time is agreed, there is no fixed minimum notice period. The guidance says this can be particularly useful where the business is large and a visit would cause little disruption, or where the taxpayer has asked for a visit.

If no time can be agreed, Revenue Scotland must choose a reasonable time and give at least 7 days’ written notice. The written notice must explain the possible consequences of obstructing the inspection. If the inspection has tribunal approval, the notice must say that as well.

Where the occupier is a company or another business entity, Revenue Scotland says it must be satisfied that agreement to the inspection, or written notice of it, is given to an appropriately senior person such as a director, site manager or partner.

The guidance also says that if Revenue Scotland arranges a document inspection visit, it may consider issuing an information notice so the business knows what records should be produced.

For an unannounced inspection, Revenue Scotland says it must have reasonable grounds for believing that advance notice would seriously prejudice the assessment or collection of tax. If that condition is met, the inspection may be carried out at any reasonable time.

At the start of an unannounced inspection, Revenue Scotland must provide written notice to the occupier if present, or to a person who appears to be in charge if the occupier is absent. If no such person is present, the notice must be left in a prominent place on the premises. If that is not possible, the guidance says it will be delivered to the occupier’s main postal business address. As with announced inspections, the notice must mention the possible consequences of obstruction and must mention any tribunal approval.

The source also says that the occupier can refuse entry to Revenue Scotland or a person authorised by it. The consequences of refusal are dealt with elsewhere in the official material.

On timing, the guidance says that unless the occupier agrees to the proposed time, all inspections, including unannounced ones, must be at a reasonable time. What counts as reasonable depends on the business, but is generally when the premises are open or staff are present. Most proposed times will be between 9am and 5.30pm on weekdays, but other times may be appropriate, including night visits where that is the normal opening time.

The guidance adds that a visit can continue after normal closing time if the person receiving the inspection agrees. It also says most businesses should be able to accommodate a visit with at least seven days’ notice, although there may be good business reasons for asking for a longer delay, and Revenue Scotland says it will consider those representations carefully.

Finally, when leaving the premises, Revenue Scotland says it will tell the person receiving the inspection what happens next, for example whether it will return, whether the inspection is finished and an outcome letter will follow, or whether the wider enquiry will continue in other ways.

What this means in practice

The starting point is that an inspection is usually meant to be organised, not sprung on the business. In most cases, Revenue Scotland will try to arrange a convenient visit so that the right staff, records and assets are available. That is intended to make the inspection more efficient and less disruptive.

If you can agree a date and time, the process is relatively informal. There is no mandatory notice period if the time is agreed. But that does not mean the visit is casual. It is still an official inspection carried out under statutory powers.

If you cannot agree a time, the position becomes more formal. Revenue Scotland must select a reasonable time and give written notice at least 7 days in advance. That written notice matters. It should tell you when the inspection is to happen and warn about obstruction. If tribunal approval has been obtained, that should also be stated.

An unannounced inspection is meant to be exceptional. The official test is not simply that surprise would be useful. Revenue Scotland must have reasonable grounds for believing that advance notice would seriously prejudice the assessment or collection of tax. In practical terms, that points to cases where warning the occupier could materially interfere with the inspection or with the tax enquiry.

The guidance also makes clear that business premises are not automatically open to entry on demand. The occupier can refuse entry. That does not necessarily end the matter, because Revenue Scotland may have other powers or may seek tribunal involvement, but the source is clear that refusal is possible.

How to analyse it

If you are trying to work out whether an inspection is being handled properly, the useful questions are:

• Is this an announced inspection or an unannounced one?
• If announced, was a time actually agreed with someone who had authority to agree it?
• If no time was agreed, was at least 7 days’ written notice given?
• Was the notice given to an appropriately senior person if the occupier is a company or other business?
• Does the notice explain the possible consequences of obstruction?
• If tribunal approval was obtained, does the notice say so?
• If the inspection is unannounced, is there an apparent basis for saying that advance notice would seriously prejudice the assessment or collection of tax?
• Is the proposed time objectively reasonable for this particular business?
• If the visit is mainly about documents, has Revenue Scotland made clear what records are expected to be available?
• When the officers leave, have they explained what happens next?

For conveyancers, advisers and in-house teams, the practical preparation point is simple: identify who in the business is authorised to deal with inspection arrangements, who can receive formal notice, and where records are kept if a document inspection is expected.

Example

A retailer is contacted by Revenue Scotland about an inspection of its trading premises. The officer speaks to the store manager, who has authority to deal with regulatory visits, and a date is agreed for the following week. Because the time is agreed, the guidance says there is no need for a minimum notice period.

By contrast, if the retailer says the proposed date is not possible and no alternative can be agreed, Revenue Scotland would need to choose a reasonable time and give at least 7 days’ written notice. If the business normally trades late into the evening, a late visit might still be a reasonable time. If it only operates during normal weekday hours, a night visit would usually be harder to justify on the guidance.

Why this can be difficult in practice

The most fact-sensitive issue is what counts as a reasonable time. The guidance gives broad indicators, not a rigid rule. A time that is reasonable for a warehouse, a restaurant, a nightclub and a professional office may be very different.

Another area of judgement is authority within a business. The guidance refers to an appropriately senior person such as a director, site manager or partner, but real businesses often have more complex structures. Whether notice was given to the right person may matter if the business later says the visit was not properly arranged.

Unannounced inspections can also be contentious. The official threshold is that advance notice would seriously prejudice the assessment or collection of tax. That is a significant test, but the guidance does not spell out every situation in which it is or is not met. In practice, disputes may arise over whether the circumstances genuinely justified a visit without warning.

There is also a difference between refusing entry and obstructing an inspection. The source says the occupier can refuse entry, while also requiring notices to explain the possible consequences of obstruction. The exact legal consequences will depend on the wider statutory framework and any tribunal approval, so the distinction should not be glossed over.

Key takeaways

• Revenue Scotland says inspections of business premises must be either announced or unannounced, and most will be announced.
• If no inspection time is agreed, Revenue Scotland must usually give at least 7 days’ written notice and choose a reasonable time.
• Unannounced inspections are only for cases where advance notice would seriously prejudice the assessment or collection of tax.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Guidance on Announced and Unannounced Business Premises Inspections

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