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HMRC internal manual

Compliance Handbook

From
HM Revenue & Customs
Updated
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Assessing Time Limits: Extended time limits: Overview

During a compliance check, you may establish that

  • all taxes have not been assessed or accounted for, or
  • sums have been over-repaid or wrongly deducted.

You will need to decide what action you can take to recover this tax. That action may be an assessment, see CH51250, which must follow the assessing time limits outlined at CH51300.

In certain circumstances the time limits for assessing are extended beyond the normal time limit of 4 years from the end of the relevant tax period described in CH51700.

The extended time limits are

  • 6 years from the end of the relevant tax period, or
  • 20 years from the end of the relevant tax period.

Whether you can use the 6-year or 20-year time limit depends on

  • the type of tax
  • whether the person’s behaviour, or that of a person acting on their behalf, has led to the loss of tax, or
  • whether the person has failed to comply with certain obligations.

The 6-year time limit only applies for income tax, capital gains tax, corporation tax, stamp duty land tax, stamp duty reserve tax and petroleum revenue tax.

You can find more information about the 6-year time limit in CH53300 and the 20-year time limit in CH53600.

There are other time limits for indirect taxes and assessing penalties, see CH53150.

FA08/SCH39

FA09/SCH51