03 May 2019
Richard Jeens and Rose Swaffield look at the broader questions around statutory time limits and how they apply to HMRC’s ability to investigate a taxpayer’s affairs and raise assessments of tax.
Both the loan charge and diverted profits tax (DPT) rules show that there is more to statutory time limits than the technical analysis. In practice, there are an increasing number of ways by which HMRC can seek to challenge ‘old and cold’ arrangements. In particular, given the limits on relying on past clearances in an evolving political climate, taxpayers need to take care to establish (and preserve) the evidence supporting their technical and factual position.
This article was first published in the 3 May edition of Tax Journal.
Time limit traps: lessons from the 2019 loan charge
This material is provided for general information only. It does not constitute legal or other professional advice.
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