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Open Consultation - Extension of offshore time limits - Tax agent blog

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We published an Extension of offshore time limits consultation on 19 February 2018, which is open for comment until 11:45pm on 14 May 2018.

The consultation paper relates to the government’s plans to give HMRC more time to assess tax in cases involving offshore income, gains or chargeable transfers.

Presently, where there has been a loss of tax, HMRC has four years to raise a tax assessment or issue a notice of determination if a taxpayer has made a mistake and six years if the taxpayer has been careless. However, it can take HMRC longer to establish the facts about offshore transactions, especially where complex offshore structures are involved.

Extending the time limit to 12 years will provide HMRC with more time to determine the correct amount of tax due. The taxes within scope of this measure are income tax, capital gains tax and inheritance tax. We are currently consulting on the details of the proposals, including whether to extend the proposal to corporation tax.

We hope you will take the opportunity to read the consultation document and provide feedback.

Your feedback is invaluable not only in informing the development of policy, but also in providing us with a clearer understanding of the needs of our customers.

Feedback should be sent by e-mail to:, using the subject heading “Extension of Offshore Time Limits Consultation”,

or by post to:

Ms Grusheka Lowton
Extension of Offshore Time Limits Consultation
HM Revenue and Customs
Room 3C/04
100 Parliament Street

Thank you for your support

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