The current time limits to assess non-compliance are 4,6 and 20 years, which depend on whether the person made a genuine mistake, failed to take reasonable care or acted deliberately to evade tax.
HMRC has announced that it intends to issue a consultation document in Spring 2018 to extend the time limits so that it can assess at least 12 tax years, irrespective of the behaviour. The purpose of the increase is to allow HMRC sufficient time to review and utilise the information in its possession.
Under the Requirement to Correct consultation, HMRC proposed to extend the time limits to investigate and assess offshore non-compliance. If HMRC bring in this new power, people with offshore assets that have not paid the correct amount of tax may have to settle liabilities far in excess of those based in the UK where the 4 and 6 year time limits would have previously applied. The new proposals reinforce how important it is that UK residents with offshore assets should ensure their historical tax affairs are in order.