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HMRC internal manual

Enquiry Manual

Partnerships: Assessments for Pre-SA Years

TMA70/S36(2) (Old)

A partnership assessment can be made at any time within 20 years of the end of the year of assessment if it is made to make good a loss of tax or NIC attributable to the fraudulent or negligent conduct of any partner, or anyone acting on his behalf.

If such an assessment is made, it is to be made on the partnership (but excluding any company which is a member of the partnership) irrespective of any default by or on behalf of any other partner.