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We are asking for views on the design principles for legislation to implement a new minimum tax assessment time limit of 12 years for HMRC to make assessments or notices of determination in cases involving offshore income, gains or chargeable transfers.
HMRC is extending the time limit because it can take much longer to establish the facts about offshore transactions, particularly if they involve complex offshore structures. More time is needed to address situations where the current assessment time limits of 4 and 6 years for offshore non-compliance are not long enough to establish the facts, and determine and assess the amount of tax due.
You are invited to comment on aspects of the design principles explained in the consultation document ‘Extension of Offshore Time Limits’.
If responding by email, please include the subject heading ‘Extension of offshore time limits consultation’.