Commentary

A4.325A Extended time limits—loss of tax involving offshore matter or offshore transfer

Administration and compliance

A4.325A Extended time limits—loss of tax involving offshore matter or offshore transfer

A4.325A Extended time limits—loss of tax involving offshore matter or offshore transfer

For 2013/14 onwards for loss of tax brought about carelessly, and for 2015/16 onwards in all other cases, extended time limits for making an assessment to income tax and capital gains tax apply where the loss of tax involves either an offshore matter, or an offshore transfer which makes the lost tax significantly harder to identify1. This would include cases where, as a result, HMRC was significantly less likely to become aware of the lost tax or was likely to become aware of it at a significantly later time2.

In these cases, the assessment can be made up to 12 years after the tax year to which the loss relates, unless TMA 1970, s 36(1A) (see A4.325) or any other provision provides for a longer time limit3.

Lost tax involves an offshore matter if it relates to4:

  1.  

    •     income from a source in a territory outside the UK

  2.  

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial