CIOT raises concerns over extension of time limits on tax investigations

21/05/2018 News Team

UK tax body - The Chartered Institute of Taxation (CIOT) - has criticised the UK Government’s proposal to extend significantly the tax assessment time limits indiscriminately in cases involving offshore matters.

The Institute believes that the case for such a large and broadly applied increase has not been made and risks resulting in unfairness for taxpayers and perverse incentives toward the care taken with tax returns.

At the Autumn Budget 2017, the Government announced that the assessment time limit for cases of mistakes or non-deliberate offshore tax non-compliance will be increased to at least 12 years after the end of the relevant tax year or relevant period. Where there is deliberate non-compliant behaviour, the current time limit of 20 years will remain, whether offshore matters are involved or not.


HMRC said that the additional time is needed to address situations where the current assessment time limits of four and six years are not sufficient to establish the facts and determine and assess the amount of tax due.


The CIOT said that whilst it supports HMRC’s efforts to tackle offshore tax evasion and agrees that the Government should have appropriate powers and resources for combatting and investigating it. However, it has concerns about the plan to extend offshore time limits in the way proposed.

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