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HMRC internal manual

Compliance Handbook

Assessing Time Limits: Extended time limits: Reliance on another person

The extended time limits apply whether the loss of tax was brought about carelessly, see CH53400, or deliberately, see CH53700, by the person to be assessed or by another person acting on behalf of that person.

The term ‘another person acting on behalf of that person’ has a very wide meaning. It is not limited to, say, a ‘tax accountant’ or other professional representative or adviser. It may also include, but again is not limited to,

  • an employee
  • an officer of a company
  • a fellow group company
  • a member of a VAT group
  • a settlor or beneficiary.

Where HMRC might intend to allege that accountancy is carelessly or deliberately wrong, the case should be submitted to a compliance accountant before a decision letter is issued, see ARTG2190.