CH123550 | Offshore matters: requirement to correct certain offshore tax non-compliance: failure to correct - penalty assessments - time limits

From HM Revenue & Customs · Compliance Handbook

You must check the date from which these rules apply for the tax or duty you are dealing with. See CH123050 for full details.

Assessment time limits

An assessment in respect of uncorrected relevant offshore tax non-compliance must be made before the end of the relevant period for that non-compliance and will depend on the time limits for assessing a penalty relating to the original non-compliance that was not corrected.

Type of offence	Relevant period
Failure to notify	12 months beginning with - the end of the appeal period for the assessment of tax unpaid by reason of the failure.
Failure to submit a return	12 months beginning with - the end of the appeal period for the assessment of the liability to tax which would have been shown in the return, or if there is no such assessment, the date on which that liability is ascertained.
Inaccuracy in a return	12 months beginning with - the end of the appeal period for the decision correcting the inaccuracy, or if there is no assessment to the tax concerned the date on which the inaccuracy is corrected.

Appeal period

All references to appeal period are to the period during which

an appeal could be brought, or
an appeal has been brought but has not been finally determined or withdrawn.

FA07/SCH24/PARA13 (2) and (7)

Section 67 and Schedule 18 Finance Act (No 2) 2017