Assessment time limits: applying the time limits to the notified date
Problems arise when an assessment is made close to the time limit for assessing. An officer may make an assessment in time but it may not be notified until later. In such cases we must always be able to demonstrate that the assessment was made within the prescribed time limits.
We have increasingly faced challenges in this area, particularly in respect of VAT assessments, and we acknowledge that it is undesirable that our time limit rules should attach to a ‘made’ date not routinely disclosed to tax and duty payers.
Therefore, for all assessments made on or after 1 March 2001 as a matter of policy we will rely on the date of notification of an assessment as the material date for time limit purposes.
It is consequently essential that assessments are notified within the statutory time limits prescribed in the Finance Act for the making of assessments.