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HMRC internal manual

Compliance Handbook

Assessing Time Limits: Extended time limits: 6-year time limit

The 6-year time limit only applies for income tax, capital gains tax, corporation tax, inheritance tax (where an IHT account has been delivered and payment made and accepted in full satisfaction of the tax due), stamp duty land tax, stamp duty reserve tax and petroleum revenue tax.

An assessment (or IHT action) to recover under-assessed or over-repaid tax can be made within 6 years of the end of the relevant tax period where the under-assessment or over-repayment is due to the careless, see CH53400, behaviour of

  • the person, see CH51600 or
  • another person acting on their behalf, see CH53200.

The 6-year time limit does not apply where the tax to be assessed as a result of a person’s careless behaviour is VAT, insurance premium tax, aggregates levy, climate change levy, landfill tax or excise duty.

You can find details of the time limits that apply for each type of assessment in tables at CH56000+. You should check the appropriate table before making your assessment.

Before you make ETL assessments, they must be authorised by the appropriate authorising officer. ETL assessments must be authorised by the authorising officer for penalty assessments. This will normally be your manager, see CH407050.

FA08/SCH39/PARA9

FA08/SCH39/PARA41

FA08/SCH39/PARA43