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HMRC internal manual

Compliance Handbook

Assessing Time Limits: Tables of time limits for relevant taxes: Corporation Tax

1.

Assessment

HMRC determination of tax where notice to make a return issued but no return delivered, or the notice is complied with only in part

Time Limit

3 years from the day on which the power to make the determination becomes exercisable

Legislation

FA98/SCH18/PARA36(5) and PARA37(4) as amended byFA08/SCH39/PARA38 and 39

 

Assessment

Company’s self-assessment to displace an HMRC determination by filing return

Time Limit

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

Legislation

FA98/SCH18/PARA40(3) as amended by FA08/SCH39/PARA40

 

2.

Assessment

Company’s routine self-assessment where no HMRC determination has been made

Time Limit

4 years from the end of the accounting period.

Legislation

FA98/SCH18/PARA46(1) amended by FA08/SCH39/PARA 42(2)

 

3.

Assessment

“Discovery” assessment (or determination of losses, etc) where loss of tax not due to careless or deliberate behaviour

Time Limit

4 years from the end of the accounting period

Legislation

FA98/SCH18/PARA46(1) as amended by FA08/SCH39/PARA42(2)

 

4.

Assessment

“Discovery” assessment (or determination of losses, etc) where loss of tax due to careless behaviour of the company or agent

Time Limit

6 years from the end of the accounting period

Legislation

FA98/SCH18/PARA46(2) and PARA46(2B) as substituted by FA08/SCH39/PARA42(3)

 

5.

Assessment

“Discovery” assessment (or determination of losses, etc) where loss of tax due to deliberate behaviour of the company or agent

Time Limit

20 years from the end of the accounting period

Legislation

FA98/SCH18/PARA46(2A) and PARA46(2B) as substituted by FA08/SCH39/PARA42(3)

 

6.

Assessment

“Discovery” assessment (or determination of losses, etc) where loss of tax due to company’s failure to provide information about an avoidance scheme

Assessment

If the company has a reasonable excuse for its failure with no unreasonable delay thereafter it is deemed not to have failed

Time Limit

4 years from the end of the accounting period

Legislation

TMA70/S118(2) (applied by FA98/S117) and FA98/SCH18/PARA46(1) as amended by FA08/SCH39/PARA42(2)

 

Assessment

If the company has no reasonable excuse and/or did delay unreasonably thereafter it will have failed

Time Limit

20 years from the end of the accounting period

Legislation

FA98/SCH18/PARA46(2A) and PARA46(2B) as substituted by FA08/SCH39/PARA42(3)

 

Assessment

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

Legislation

SI 2009 No 403 Article 8

 

7.

Assessment

“Discovery” assessment (or determination of losses, etc) where loss of tax due to failure to notify liability to the tax

Assessment

If the company has a reasonable excuse for its FTN with no unreasonable delay thereafter it is deemed not to have failed

Time Limit

4 years from the end of the accounting period

Legislation

TMA70/S118 (2) (applied by FA98/S117) and FA98/SCH18/PARA46(1) as amended by Para FA08/SCH39/PARA42(2)

 

Assessment

If the company has no reasonable excuse and/or did delay unreasonably thereafter it will have failed

Time Limit

20 years from the end of the accounting period.

Legislation

FA98/SCH18/PARA46(2A) and PARA46(2B) as substituted by FA08/SCH39/PARA42(3)

 

Assessment

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

Legislation

SI 2009 No 403 Article 8

 

8.

Assessment

Assessment to withdraw or reduce CITR (Community Investment Tax Relief) - No careless or deliberate behaviour

Time Limit

6 years from the end of the accounting period for which the relief was obtained

Legislation

FA02/SCH16/PARA27 as amended by FA08/SCH39/PARA48

 

Assessment - Careless behaviour

Time Limit

6 years from the end of the accounting period for which the relief was obtained

Legislation

FA02/SCH16/PARA27 as amended by FA08/SCH39/PARA48

 

Assessment -Deliberate behaviour

Time Limit

20 years from the end of the accounting period for which the relief was obtained

Legislation

FA02/SCH16/PARA27 as amended by FA08/SCH39/PARA48

 

9.

Assessment

Assessment to recover excessive repayments - No careless or deliberate behaviour

Time Limit

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 the enquiry into a relevant company tax return by way of final closure notice

Legislation

FA98/SCH18/PARA53 as amended by FA08/SCH39/PARA44

 

Assessment - Careless behaviour

Time Limit

The latest of

  • (i) 6 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 the enquiry into a relevant company tax return by way of final closure notice

Legislation

FA98/SCH18/PARA53 as amended by FA08/SCH39/PARA44

 

Assessment - Deliberate behaviour

Time Limit

The latest of

  • (i) 20 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 the enquiry into a relevant company tax return by way of final closure notice

Legislation

FA98/SCH18/PARA53 as amended by FA08/SCH39/PARA44

 

10.

Assessment

Assessment to additional CT where Petroleum Revenue Tax has been repaid. - No careless or deliberate behaviour

Time Limit

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

Legislation

CTA10/S300

 

Assessment - Careless behaviour

Time Limit

6 years from the end of the accounting period

Legislation

FA98/SCH18/PARA46 as amended by FA08/SCH39/PARA42

 

Assessment - Deliberate behaviour

Time Limit

20 years from the end of the accounting period

Legislation

FA98/SCH18/PARA46 as amended by FA08/SCH39/PARA42