Guidance on Premises Inspection for Valuation and Tax Compliance

Revenue Scotland inspections of property for valuation purposes

Revenue Scotland can enter and inspect premises, including homes, to value, measure, or assess the character of a property where this is reasonably needed to check a person’s devolved tax position. However, it is not a general power of entry: the visit must follow set procedures, including agreement with the relevant person or tribunal approval, and officers must show their authority if asked.

• The inspection must be for a valuation-related purpose only: valuing the property, measuring it, or deciding its physical character.
• Revenue Scotland can only use this power where the inspection is reasonably required to check devolved tax, such as LBTT.
• An inspection can go ahead by agreement if the occupier, or the person controlling vacant premises, agrees the time and receives written notice.
• If there is no agreement, tribunal approval is needed, with at least seven days’ written notice to any relevant person named by the tribunal.
• The written notice for a tribunal-approved visit must say that obstruction may have consequences and that the notice has tribunal approval.
• Revenue Scotland may bring a specialist such as a surveyor or valuer, and the officer must produce evidence of authority if the occupier or person in charge asks for it.

Scroll down for the full analysis.

Revenue Scotland inspections of premises for valuation: when they can enter and what safeguards apply

This page explains Revenue Scotland’s power to enter and inspect premises for valuation purposes. The power matters because devolved land taxes, including LBTT, can depend on the value, size, layout, and character of a property. The official guidance allows inspections, including of dwellings, but only where this is reasonably required to check a person’s devolved tax position and only if certain procedural conditions are met.

What this rule is about

Some tax questions cannot be resolved from documents alone. Revenue Scotland may need to see a property in order to value it, measure it, or understand its physical character. That can affect the tax analysis, for example where the nature or extent of the property is relevant to the amount of tax due.

The guidance is dealing with a specific investigatory power: entry and inspection of premises for valuation purposes. It is not a general right to enter whenever Revenue Scotland wishes. The inspection must be for a defined purpose and must be reasonably required to check a devolved tax position.

What the official source says

According to the guidance, Revenue Scotland may enter and inspect any premises, including a dwelling, and any other property on the premises, if the inspection is for the purpose of:

• valuing the premises or other property,
• measuring it, or
• determining its character.

That inspection power only applies where the inspection is reasonably required for checking any person’s devolved tax position.

Revenue Scotland may also bring another person to assist with the valuation, measurement, or determination. That person does not have to be a Revenue Scotland employee.

If asked, the officer must produce evidence of their authority to carry out the inspection. The request can come from:

• the occupier of the premises, or
• another person who appears to the officer to be in charge of the premises or property.

The guidance says a valuation inspection can only take place if one of two conditions is met.

Condition A is agreement. The inspection is carried out at a time agreed by a relevant person, and that person has been given written notice of the agreed time. A relevant person means:

• the occupier, or
• if the occupier cannot be identified or the premises are vacant, a person who controls the premises.

Condition B is tribunal approval. The inspection has been approved by the tribunal, and any relevant person specified by the tribunal has been given written notice of the inspection time at least seven days in advance. That notice must say:

• what the possible consequences are if Revenue Scotland, or someone authorised by it, is obstructed during the inspection, and
• that the notice has been approved by the tribunal.

The guidance also says that when the inspection team leaves, they will tell the person receiving the inspection what happens next. For example, they may say the inspection will continue the next day, that it has finished and the outcome will be written up, or that the inspection is complete but the wider enquiry will continue in other areas.

What this means in practice

The practical effect is that Revenue Scotland can inspect property physically, even residential property, but it cannot do so informally or without procedural safeguards.

There are three main limits built into the guidance.

• The inspection must be for a valuation-related purpose: value, measurement, or character.
• It must be reasonably required for checking a devolved tax position.
• It must either be agreed in advance with the relevant person or approved by the tribunal with the required notice.

For taxpayers, occupiers, and conveyancers, this means the first questions are usually not just “Can they inspect?” but “Why is an inspection needed?” and “Have the correct steps been followed?”

The reference to “character” is important. This is broader than simple market value. It can include the physical nature of the premises, which may matter where tax treatment depends on what the property actually is in substance.

The ability to bring a non-employee assistant also matters in practice. Revenue Scotland may use a valuer, surveyor, or other specialist if that person is needed to help assess the property. The guidance expressly allows that.

How to analyse it

A sensible way to assess an inspection request is to work through the following points.

1. What is the tax issue?

Identify what aspect of the devolved tax position Revenue Scotland says it is checking. The guidance does not give examples, but the inspection must be linked to checking a person’s devolved tax position, not to a general fact-finding exercise with no valuation purpose.

2. Is the inspection really for valuation, measurement, or character?

The stated purpose should fit one of those categories. If the issue appears unrelated to the physical property, that may raise questions about whether this particular power is being used for the right reason.

3. Is the inspection reasonably required?

This is an important limiting phrase. It suggests that the inspection should be genuinely needed for the tax check being carried out. The guidance does not define the test in detail, so this may depend on the facts.

4. Has condition A or condition B been satisfied?

If the visit is by agreement, the agreed time must also be confirmed in writing to the relevant person.

If there is no agreement, tribunal approval is needed. In that case, any relevant person specified by the tribunal must receive at least seven days’ written notice, and the notice must contain the information required by the guidance.

5. Who is the relevant person?

Usually this will be the occupier. If the occupier cannot be identified or the premises are vacant, the relevant person is a person who controls the premises. That matters because the notice and agreement requirements are tied to that person.

6. Has authority been shown if requested?

If the occupier or person apparently in charge asks for evidence of authority, the officer must produce it.

7. Who is attending the inspection?

If Revenue Scotland brings someone else, that is permitted where that person is needed to assist with valuation, measurement, or determining character. The guidance makes clear that the assistant need not be a Revenue Scotland employee.

Example

Illustration: Revenue Scotland is checking the devolved tax treatment of a land transaction and considers that the physical extent and nature of the property are important to that analysis. It asks to inspect the premises to measure parts of the site and assess the property’s character. If the occupier agrees a date and receives written notice of that agreed time, the inspection may proceed under condition A. If the occupier does not agree, Revenue Scotland would need tribunal approval under condition B before carrying out the inspection, and the required written notice would have to be given.

Why this can be difficult in practice

The guidance states the power in broad terms, but some parts are fact-sensitive.

First, “reasonably required” is not mechanically defined here. There may be room for disagreement about whether a physical inspection is truly necessary, especially if plans, photographs, valuations, or other records already exist.

Second, identifying the correct “relevant person” may not always be straightforward. Vacant property, mixed occupation, managed sites, or uncertain control arrangements can complicate who must agree to the inspection or who must receive notice.

Third, the term “character” is potentially wide. In some cases, there may be debate over whether the proposed inspection is genuinely about the character of the property or whether Revenue Scotland is trying to answer a broader question through this power.

Fourth, the guidance refers to possible consequences of obstruction, but those consequences are dealt with elsewhere. In practice, where access is disputed, the procedural route taken by Revenue Scotland can matter a great deal.

Finally, this is guidance on investigatory powers. The legal effect of an inspection and any dispute about it must still be understood in the wider statutory framework, including the tribunal approval process referred to in the source.

Key takeaways

• Revenue Scotland can inspect premises, including dwellings, for valuation, measurement, or determining character, but only where this is reasonably required to check a devolved tax position.
• An inspection must either be agreed in advance with the relevant person and confirmed in writing, or be approved by the tribunal with the required written notice.
• If asked, the officer must show authority, and Revenue Scotland may bring in a specialist assistant where needed for the valuation-related task.

This page was last updated on 24 March 2026

Useful article? You may find it helpful to read the original guidance here: Guidance on Premises Inspection for Valuation and Tax Compliance

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