Visits to Taxpayers

For visits between 1st April 2009 and 31st March 2010 taxpayers can be required to produce VAT records dating back to 1st April 2006 if the business started before that date.

Extended Time-Limit

The 20-year extended time-limit continues to apply but the circumstances in which it applies have changed.

For accounting period ending on or before 31st March 2006 assessments could only be made using the 20 year extended time-limit for periods when tax was lost:-

  • Due to dishonest evasion
  • Where a person has been convicted of fraud or
  • Where there was a failure to notify liability to register without reasonable excuse


For accounting periods ending after 31st March 2006 the extended time-limit applies:-

  • Where VAT has been lost due to the deliberate behaviour of the taxpayer, or someone acting on their behalf.
  • For certain failures to notify, irrespective or behaviour.


Failure to Notify Liability to Register

Before 1st April 2009 if there a person failed to notify liability to register for VAT and had a reasonable excuse, assessments were restricted to three years as a matter of policy.

Where an assessment is made as a result of a failure to notify liability to register for VAT on or after 1st April 2010 the extended time-limit applies regardless of here being a reasonable excuse for the failure.

Failure to Notify Avoidance Schemes

There will be a new 20 year extended time-limit in cases where a person has failed to notify an avoidance scheme for periods ending on or after 1st April 2010. This will apply to VAT, income tax, corporation tax and capital gains tax.

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