Taxes Consolidation Act 1997 section 959P

Expression of doubt

Section 959P allows a chargeable person who is uncertain about the correct application of tax law to include a formal "expression of doubt" with a self-assessment return, and sets out the conditions and consequences of doing so.

• A chargeable person may file a return based on their best interpretation of the law and include a letter of expression of doubt, provided the return and supporting documentation are delivered on time
• A genuine expression of doubt treats the return as a full and true disclosure, with any additional tax payable within one month of the amended assessment rather than on the original due date
• Revenue may refuse to accept an expression of doubt as genuine where published guidelines indicate the matter is sufficiently clear, or where the taxpayer was seeking to evade or avoid tax
• A taxpayer may appeal a Revenue officer's rejection of the expression of doubt to the Appeal Commissioners within 30 days of the decision