Consultation on the implementation of a new minimum tax assessment time limit of 12 years.
HMRC is consulting on the design principles for legislation – announced in the autumn Budget – to implement a new minimum time limit of 12 years for making tax assessments or notices of determination in cases involving offshore income, gains or chargeable transfers.
It is in response to how long it can take to establish the facts about offshore transactions, in particular those involving complex offshore structures. The current time limits of four and six years for offshore non-compliance are sometimes to short to establish the facts, and determine and assess how much tax is due.
Responses to the consultation should be emailed to consult.nosafehavens@hmrc.gsi.gov.uk by 14 May 2018.