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HMRC internal manual

Enquiry Manual

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HM Revenue & Customs
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Reopening earlier years: assessments: authorisation required for ETL assessments

Before you make Extended Time Limit (ETL) assessments they must be authorised by the appropriate Authorising Officer. ETL assessments must be authorised by the Authorising Officer for penalty assessments and determinations. This will normally be your manager, see CH407050.

If the case is within a project managed avoidance scheme, the technical lead (via the enquiry project manager where one has been appointed) should be consulted before ETL assessments are considered.

From 1 April 2010 an ETL assessment is

  • any assessment where the assessing time limit is anything other than the normal time limit, see CH52100 
  • any assessment where the normal time limit is extended because the underlying behaviour is either careless or deliberate, see CH53700 
  • any assessment where the normal time limit is extended to 20 years for failure to notify cases and avoidance schemes, see CH53600.

You normally request authorisation for ETL assessments using form 64D-4 (New), which is available in SEES. You must provide the Authorising Officer with evidence of the specific behaviour that resulted in the loss of tax for each year or period for which you are requesting ETL assessments. The evidence you hold of the person’s behaviour may apply across several years or periods, in which case you will need to explain this. If you have already recorded evidence of a person’s behaviour on a PDAC for the purpose of authorising penalties, you can simply refer to the PDAC on the 64D-4 (New) because there will be tax years or periods you wish to issue ETL assessments for, that are not covered by the PDAC.