Other Matters

Extension of offshore time limits

The assessment time limits have been increased for offshore income and gains to 12 years. Similarly the time limits for proceedings for the recovery of inheritance tax are increased to 12 years where the lost tax involves an 'offshore matter'. Where an assessment involves a loss of tax brought about deliberately the assessment time limit is 20 years after the end of the year of assessment and this time limit will not change.

The legislation does not apply to corporation tax or where HMRC has received information from another tax authority under automatic exchange of information.

The potential extension of time limits apply from the 2013/14 tax year where the loss of tax is brought about by careless behaviour and from the 2015/16 tax year in other cases.

Comment

Assessment time limits are ordinarily four years (six years in the case of carelessness by the taxpayer). The justification for the extension of time limits is the longer time it can take HMRC to establish the facts about offshore transactions, particularly if they involve complex offshore structures.

The legislation cannot be used to go back earlier than 2013/14. If there has been careless behaviour HMRC can make an assessment for up to 12 years from 2013/14 in respect of offshore matters but HMRC could not raise an assessment for 2012/13 or earlier (unless there is deliberate behaviour by the taxpayer).

Review of other time limits

A report will be issued in March comparing the time limits for the recovery of lost tax involving an offshore matter with other time limits.

Insurance Premium Tax

A call for evidence will be issued on where improvements can be made to ensure that Insurance Premium Tax operates fairly and efficiently.

Aggregates Levy

A discussion paper has been issued launching a review of the Aggregates Levy including the Terms of Reference and information on timing and scope of the review.

Tackling tax avoidance, evasion and other forms of non-compliance

A policy paper has been issued which:

  • outlines HMRC's strategy and approach to compliance for different taxpayer types
  • details the government's record in addressing areas where risks of non-compliance have been identified
  • provides a summary of the government's investment in HMRC and its commitment to further action.

Comment

The policy paper lists details of over 100 measures the government has introduced since 2010 covering avoidance, evasion and non-compliance.

Late payments made to small businesses

In his speech, the Chancellor announced that further action will be taken to tackle the issue of late payments by large businesses to small businesses. A full response to a call for evidence issued in 2018 will be published shortly. As a first step the government will require Audit Committees to review payment practices and report on them in their Annual Accounts.

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