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HMRC internal manual

Compliance Handbook

From
HM Revenue & Customs
Updated
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Assessing Time Limits: Tables of time limits for relevant taxes: Stamp Duty Land Tax

 

  Assessment
  Time limit Legislation
  1 Assessment on a person in a case involving loss of tax brought about with no careless or deliberate behaviour.
  4 years after the effective date of the transaction. FA03/SCH10/PARA31(1) as amended by FA09/SCH51/PARA15(5)
  2 Assessment of an amount due from a person in a case involving a loss of tax brought about carelessly by the purchaser or by another person acting on the purchaser’s behalf, or a person who was a partner of the purchaser at the relevant time.
  6 years after the effective date of the transaction. FA03/SCH10/PARA31(2) as amended by FA09/SCH51/PARA15(6)
  3 Assessment of an amount due from a person in a case involving a loss of tax brought about deliberately by the purchaser or by another person acting on the purchaser’s behalf, or a person who was a partner of the purchaser at the relevant time.
  20 years after the effective date of the transaction. FA03/SCH10/PARA31(2A) as amended by FA09/SCH51/PARA15(6)
  4 Assessment of a penalty under FA03/SCH14**
  4 years from the date the penalty is incurred* or, if the penalty is tax-geared, 3 years from the date the tax is finally determined if later, subject to 7 below in the case of deceased persons.
  FA03/SCH14/PARA8(2) as amended by FA09/SCH51/PARA16(2)      
  5 Assessment of a penalty under FA03/SCH14** in a case involving loss of tax brought about carelessly by the person or by another person acting on that person’s behalf 6 years from the date the penalty is incurred* if later than the date given by 4 or 7. FA03/SCH14/PARA8(4A) as amended by FA09/SCH51/PARA16(4)
  6 Assessment of a penalty under FA03/SCH14** in a case involving loss of tax brought about deliberately by the person or by another person acting on that person’s behalf    
  20 years from the date the penalty is incurred* if later than the date given by 4 or 7. FA03/SCH14/PARA8(4B) as amended by FA09/SCH51/PARA16(4)
  7 Penalty assessment for a deceased person.
  4 years after the date the penalty is incurred* or, if the penalty is tax geared, 3 years from the date when tax is finally determined, if later, provided that the tax assessment is made no more than 6 years from the relevant date.
  FA03/SCH14/PARA8(3) as amended by FA09/SCH51
  • In the case of a daily penalty the assessment time limit runs from the date the penalty began to be incurred.

** Not penalties under FA2007/SCH24, these are subject to SCH24/PARA13 time limits.