ICAS responds to Modernising Revenue Scotland’s tax administration consultation

8 July 2026

Last updated: 9 July 2026

Katie Close CA
Director of Tax, ICAS

ICAS calls for a balanced approach to digital communications that is aligned with a long-term digital roadmap for Scotland, in our response to consultation on Modernising Revenue Scotland’s tax administration.

ICAS has responded to the Scottish Government’s consultation on modernising Revenue Scotland’s tax administration framework, with a particular focus on the proposed shift towards electronic communications.

While broadly supportive of digital transformation, ICAS emphasises that changes must be grounded in accessibility, clarity and taxpayer trust and aligned with a long-term roadmap for digital tax services in Scotland.

Digital by default – with safeguards

Moving to electronic communications by default can improve efficiency and reduce administrative burdens. However, this must be accompanied by robust opt-out provisions and protections for digitally excluded taxpayers.

Digital services should be designed to encourage voluntary uptake, rather than create a two-tier system where non-digital users are disadvantaged. Clear advance communication and simple opt-out mechanisms will be critical to ensuring fairness.

Importance of taxpayer experience and trust

A key theme of our response is the need for a “taxpayer trust” approach to digitalisation. ICAS highlights that user-friendly systems, secure handling of data, and transparent communication about how information is used are essential to building confidence.

The current SETS (Scottish Electronic Tax System) platform is noted as presenting usability challenges, underlining the importance of improving system design alongside introducing new communication methods.

Risks around delivery and evidence

ICAS raises concerns about proposals to treat electronic communications as received on the day of transmission. Practical issues – such as email failures, outdated contact details or cybersecurity risks – could have significant consequences where tax liabilities or penalties are at stake.

We call for clear and accessible processes to challenge presumed delivery, supported by monitoring systems to identify undelivered or unopened communications.

Clarity and security in communication channels

While supporting flexibility in the definition of electronic communications, ICAS cautions against uncertainty around how Revenue Scotland will contact taxpayers.

Greater clarity would help mitigate risks of phishing and fraud, which may increase as digital interaction expands. Taxpayers and agents should be aware of how and where to expect communications from Revenue Scotland. Clear guidance on official channels is recommended as part of a secure framework.

Continued role for non-digital communication

ICAS agrees that paper correspondence remains a necessary alternative for those unable or unwilling to engage digitally.

It recommends that high-priority communications should, where appropriate, use recorded delivery to ensure receipt.

Alignment and future strategy

ICAS supports alignment with HMRC practices where possible, noting that consistency across tax administrations reduces confusion. However, it acknowledges that Scotland’s more transactional taxes, such as LBTT, present distinct challenges compared to ongoing compliance regimes.

Our response also highlights the opportunity for Revenue Scotland and the Scottish Government to develop a broader digital tax strategy, ensuring that changes to communications form part of a coherent long-term roadmap.

View the response