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HMRC internal manual

Compliance Handbook

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HM Revenue & Customs
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Assessing Time Limits: Tables of time limits for relevant taxes: Corporation Tax

  Assessment Time Limit Legislation
       
1 HMRC determination of tax where notice to make a return issued but no return delivered, or the notice is complied with only in part. 3 years from the day on which the power to make the determination becomes exercisable. FA98/SCH18/PARA36(5) & PARA37(4) as amended by FA08/SCH39/PARA38 & 39.
  Company’s self-assessment to displace an HMRC determination by filing return. The later of(i) 3 years from the day on which the power to make the determination becomes exercisable, and(ii) 12 months from the date of the determination.  FA98/SCH18/PARA40(3) as amended by FA08/SCH39/PARA40.
2 Company’s routine self-assessment where no HMRC determination has been made.  4 years from the end of the accounting period. FA98/SCH18/PARA46(1) amended by FA08/SCH39/PARA 42(2). 
3 “Discovery” assessment (or determination of losses, etc) where loss of tax not due to careless or deliberate behaviour.  4 years from the end of the accounting period. FA98/SCH18/PARA46(1) as amended by FA08/SCH39/PARA42(2).
4 “Discovery” assessment (or determination of losses, etc) where loss of tax due to careless behaviour of the company or agent.  6 years from the end of the accounting period.  FA98/SCH18/PARA46(2) & PARA46(2B) as substituted by FA08/SCH39/PARA42(3). 
5 “Discovery” assessment (or determination of losses, etc) where loss of tax due to deliberate behaviour of the company or agent.  20 years from the end of the accounting period. FA98/SCH18/PARA46(2A) & PARA46(2B) as substituted by FA08/SCH39/PARA42(3). 
6 “Discovery” assessment (or determination of losses, etc) where loss of tax due to company’s failure to provide information about an avoidance scheme.    
  If the company has a reasonable excuse for its failure with no unreasonable delay thereafter it is deemed not to have failed. 4 years from the end of the accounting period. TMA70/S118 (2) (applied by FA98/S117) & FA98/SCH18/PARA46(1) as amended by FA08/SCH39/PARA42(2).
  If the company has no reasonable excuse and/or did delay unreasonably thereafter it will have failed. 20 years from the end of the accounting period. FA98/SCH18/PARA46(2A) & PARA46(2B) as substituted by FA08/SCH39/PARA42(3). 
  For APs ending on or before 31 March 2010, there must also have been negligent or fraudulent conduct by the company, someone acting on behalf of the company or a person who was a partner of the company.   SI 2009 No 403 Article 8
7 “Discovery” assessment (or determination of losses, etc) where loss of tax due to failure to notify liability to the tax.    
  If the company has a reasonable excuse for its FTN with no unreasonable delay thereafter it is deemed not to have failed. 4 years from the end of the accounting period. TMA70/S118 (2) (applied by FA98/S117) & FA98/SCH18/PARA46(1) as amended by Para FA08/SCH39/PARA42(2).
  If the company has no reasonable excuse and/or did delay unreasonably thereafter it will have failed.  20 years from the end of the accounting period.  FA98/SCH18/PARA46(2A) & PARA46(2B) as substituted by FA08/SCH39/PARA42(3). 
  For APs ending on or before 31 March 2010, there must also have been negligent or fraudulent conduct by the company, someone acting on behalf of the company or a person who was a partner of the company.   SI 2009 No 403 Article 8
8 Assessment to withdraw or reduce CITR (Community Investment Tax Relief).    
  No careless or deliberate behaviour. 6 years from the end of the accounting period for which the relief was obtained.  FA02/SCH16/PARA27 as amended by FA08/SCH39/PARA48. 
  Careless behaviour 6 years as above. FA02/SCH16/PARA27 as amended FA08/SCH39/PARA48.
  Deliberate behaviour 20 years from the end of the accounting period for which the relief was obtained. FA02/SCH16/PARA27 as amended by FA08/SCH39/PARA48. 
9 Assessment to recover excessive repayments.    
  No careless or deliberate behaviour. The latest of(i) 4 years from the end of the accounting period concerned,(ii) the end of the accounting period next following that in which the amount was paid, and(iii) 3 months after the completion of an enquiry into a relevant company tax return. FA98/SCH18/PARA53 as amended by FA08/SCH39/PARA44.
  Careless behaviour. As above, substituting 6 years at (i). FA98/SCH18/PARA53 as amended by FA08/SCH39/PARA44.
  Deliberate behaviour. As above, substituting 20 years at (i). FA98/SCH18/PARA53 as amended by FA08/SCH39/PARA44. 
10 Assessment to additional CT where Petroleum Revenue Tax has been repaid.    
  No careless or deliberate behaviour. The later of(i) 4 years after the end of the accounting period, and(ii) 4 years from the end of the calendar year in which the PRT was repaid or the release or writing-off occurs. CTA10/S300
       
  Careless behaviour. 6 years from the end of the accounting period. FA98/SCH18/PARA46 as amended by FA08/SCH39/PARA42.
  Deliberate behaviour. 20 years from the end of the accounting period. FA98/SCH18/PARA46 as amended by FA08/SCH39/PARA42.