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Time limits for offshore non-compliance

Jane Moore considers the government’s plan to extend the assessment time limits for offshore non-compliance, detailing the key points to note and the reasons for the change.

Last year’s Autumn Budget included a brief mention of an impending change, which I found to be very worrying – namely, the assessment time limit for deliberate non-compliance with an offshore element being extended to 12 years (from four or six). We now have the consultation document, with more details, and I am still worried.

At present the time limits for HMRC to issue assessments or notices of determination are: four years in any case; six years where the taxpayer’s behaviour has been careless; and 20 years for deliberate behaviour (fraud, by any other name).