Consultation on the extension of offshore time limits

09 March 2018

A recent tax agent blog from HMRC highlights the consultation on the extension of offshore time limits which 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. HMRC is consulting on the details of the proposals, including whether to extend the proposal to corporation tax.


If this consultation will affect you, please do read the consultation document and provide feedback to help inform the development of policy.

The Extension of offshore time limits consultation is open for comment until 11:45pm on 14 May 2018.