The new time-limits provided in FA 2008, Sch. 39 do not come into effect until 1st April 2010. If HMRC wish to raise an extended time-limit assessment before that date they must be able to show that the taxpayer was guilty of fraud or neglect.
As a result of the new time-limits, some assessable years will become out of date for assessment on 1st April 2010:-
- In cases where there is no carelessness, two years of assessment will become out of date for assessment.
- In cases involving negligent or careless conduct, the time-limit for assessment will fall from 20 years to 6 years
- Claims that had a six-year time-limit will have a four-year limit so two years will become out of time immediately.
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