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HMRC internal manual

Fraud Civil Investigation Manual

HM Revenue & Customs
, see all updates

Where CDF offer is made up to 29 June 2014: managing the detailed disclosure process: indirect tax issues

Where you have been provided with any information relating to indirect tax issues you must be mindful of the time limits for raising your assessments.

The time limits for issuing indirect tax assessments are different from the rules for issuing direct tax assessments. Even where you have clear deliberate conduct and a 20 year overall limit, you need to be very careful that you are not excluded from assessing by other, shorter time limits.

The periods for which assessments can be raised is determined by the nature of the irregularities. Full details are provided within the VAT Assessments and Error Correction Manual (VAEC) and in VAT Notice 915.

You must always keep a regular watch on what you are being told about VAT irregularities and whether or not you have been given enough information to issue the assessments.

You must not assume that this will not be an issue later in your investigation. You might find that the ‘evidence of facts’ provided within the Outline Disclosure is sufficient to justify making assessments. If that is the case then you should issue the assessments as soon as possible and certainly within 12 months. Under no circumstances should you delay making assessments on the assumption that you will soon receive more information which will enable you to raise a better assessment. If that information never comes in, you may find yourself cut off from using what you have and the tax will be lost.

Note: A clear finding of fraud does not allow you to override the 12 months evidence of facts rule.

If you are in any doubt about the correct procedure you must make sure that you seek the appropriate advice at the earliest opportunity. 

For detailed guidance on assessing time limits see CH50000.