Commentary

V5.136 Time limit for making a VAT assessment—general

Part V5 Compliance, enforcement and appeals

V5.136 Time limit for making a VAT assessment—general

V5.136 Time limit for making a VAT assessment—general

VAT assessment—time limits

The time limits for making an assessment are described below by reference to the statutory provisions under which they are made. For the conduct giving rise to assessments under these provisions, see V5.132.

Prior to 18 July 1996, an assessment had to be made not more than one, two, six or 20 years (depending on the circumstances) after the end of a prescribed accounting period or the occurrence of some specified event. However, legislation was introduced in FA 1997 that restricted the time limit for raising assessments to a maximum of three years1 other than in certain defined circumstances, eg fraud2. The three-year limit was raised to four years with effect from 1 April 2009. Assessments must now be made not more than one, two, four or 20 years after the end of the prescribed accounting period or the occurrence of some specified event. This period is counted by excluding the day on which the prescribed accounting period ends or the event occurs3. Thus, if an assessment must be made not more than two years after the prescribed accounting period ended 30 June 1997, the assessment must be made on or before 30 June 1999. For the time when an assessment is made, see V5.131.

No time limit for reduction of VAT repayment claim

Since HMRC has powers only to raise an

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