Subject to specific exceptions, an assessment1 may not be made more than four years after the end of the prescribed accounting period2 or importation or acquisition concerned3. However, in a case involving a loss of VAT brought about deliberately by the person being assessed 'P' (or by another person acting on P's behalf)4, a case in which P has participated in a transaction knowing that it was part of arrangements of any kind (whether or not legally enforceable) intended to bring about a loss of VAT, a case involving a loss of VAT attributable to a failure by P
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