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HMRC internal manual

Enquiry Manual

Reopening Earlier Years: Discovery in Pre-SA Years: Time Limits

The normal and extended assessment time limits changed on 1 April 2010. The guidance below applies to assessments made before that date. For guidance on the time limits that apply to all assessments made on or after 1 April 2010 see CH53000+.

TMA70/S34 (pre-SA)

TMA 70/S36(1) (pre-SA)

Under the normal time limits an assessment could be made at any time not later than 6 years after the end of the year of assessment or accounting period to which it related.

This six year time limit has now passed for all pre-SA years.

The normal time limit for assessing was extended where there was a loss of tax attributable to the fraudulent or negligent conduct of the taxpayer or of a person acting on their behalf. The assessment had to be made not later than 20 years after the end of the chargeable period to which the assessment related.

In the case of a deceased person, assessments can no longer be made for pre-SA years.

See EM3340+ for operational procedures.