CH51300 | Assessing Time Limits: The Time Limits: What are the new time limits - introduction

The new aligned time limits apply, in different ways, to income tax, capital gains tax, corporation tax, VAT, insurance premium tax, aggregates levy, climate change levy, landfill tax, inheritance tax, stamp duty land tax, stamp duty reserve tax, petroleum revenue tax and excise duty.

There are four time limits within which we can issue assessments. These are

• 4 years from the end of the relevant tax period, see CH52100

• 6 years (careless) from the end of the relevant tax period, see CH53300

• 12 years (offshore) from the end of the relevant tax period, see CH53510, and

• 20 years (deliberate) from the end of the relevant tax period, see CH53600.

We explain in detail below each of the time limits.

We explain what ‘relevant tax period’ means at CH51700.

4-year time limit

The normal time limit of 4 years applies to all taxes.

See CH51820 to CH51880 for more detail about the other limitations of particular VAT assessments.

Limitations also apply for insurance premium tax, aggregates levy, climate change levy and landfill tax, see CH51920 to CH51960, and excise duty, see CH51980.

The extended time limits of 6, 12 and 20 years apply in specific circumstances, see CH53000+.

6-year time limit

The 6 year time limit applies where income tax, capital gains tax, corporation tax, inheritance tax (where an IHT account has been delivered and payment made and accepted in full satisfaction of the tax due), stamp duty land tax, stamp duty reserve tax and petroleum revenue tax has been lost as a result of the careless behaviour of the person, or another person acting on their behalf, see CH53300.

12-year time limit

The 12 year time limit applies where income tax, capital gains tax or inheritance tax (where an inheritance tax account has been delivered and payment made and accepted in full satisfaction of the tax due) has been lost and the lost tax involves an offshore matter or offshore transfer. This applies where either reasonable care has been taken, or the behaviour is careless by the person or another person acting on their behalf.

See CH53510 to find out which tax years the 12 year time limit applies.

Where the behaviour is deliberate the 20 year time limit will apply, see below.

20-year time limit

The 20 year time limit applies where

• any of the taxes in CH51200 has been lost as a result of the deliberate behaviour of the person, see CH51600, or another person acting on their behalf, see CH53200, or

• the person has failed to comply with certain obligations, see CH53900 to CH54100 inclusive, irrespective of their behaviour except assessments to income tax, capital gains tax or corporation tax for periods ending before 1 April 2010.

CH54200 provides details of the time limits that apply to deceased persons.

You can find full details of the time limits that apply for each type of assessment and transitional provisions in the tables at CH56000+. You should check the appropriate table before making your assessment.