FA 2019: offshore time limits

Adam Craggs

Constantine Christofi

FA 2019 ss 80 and 81 insert into TMA 1970 and IHTA 1984 extended time limits for assessing income tax CGT and inheritance tax (IHT) where a loss of tax arises out of or involves an ‘offshore matter’ or ‘offshore transfer’. The behaviour can be non-deliberate and the current maximum time limit of 20 years for deliberate behaviour contained in TMA 1970 s 36 will remain whether offshore matters are involved or not.

The new offshore time limit

An assessment on a taxpayer may now be made at any time up to 12 years after the end of the year of assessment to which the lost tax relates where the loss of tax arises out of or involves an ‘offshore matter’ or ‘offshore transfer’. This extends the previous time limit of four years.

Lost income tax or CGT ‘involves an offshore...

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