HMRC time limits
Posted on 17 Mar 2025, by Paul Sanders
There are specific time limits for HM Revenue & Customs (HMRC) to issue assessments to recover tax.
HMRC time limits can vary depending on the type of tax and the circumstances involved.
If HMRC discovers during a VAT check or direct tax enquiry that something has gone wrong, it will always consider how far back in time it may be able to issue assessments if the same issues also occurred in the past.
Why are assessing time limits important?
Assessing time limits ensure HMRC operates within a clear agreed timeframe.
Time limits for HMRC to issue tax assessments also provides taxpayers with a degree of finality.
Without proper consideration of time limits, HMRC enquiries or disclosures may cost more than they need to.
What affects HMRC time limits
The main consideration is generally the underlying ‘behaviour’ that led to the error in a tax return, or in a tax return not being filed.
For instance:
- Did you take reasonable care?
- Did you take professional advice?
- Was the failure or inaccuracy due to an oversight or a lack of understanding?
- Did you choose not to tell HMRC or leave something out of a return?
It is important to note, if HMRC concludes your behaviour was careless or deliberate (deliberate means fraudulent in relation to HMRC matters), the onus of proof rests with HMRC.
The time limits
For direct tax, the normal HMRC time limits for assessments are:
| Time limit | Behaviour |
| 4 years | Reasonable care / genuine mistake |
| 6 years | Careless (No extension of VAT assessing time limit for careless) |
| 12 years | Offshore matters / offshore transfers |
| 20 years | Deliberate / Tax evasion |
Where the offence relates to the Failure to Notify (“FTN”) HMRC of a tax liability, different assessing time limits apply, as follows.
| Time limit | Behavior |
| 4 years | Reasonable excuse and HMRC notified without delay after excuse ended |
| 20 years | For all other cases |
All the above HMRC time limits apply from the end of a relevant tax period.
VAT assessments do not have the six-year limit, and there are some further nuances to the time limits for VAT, these are covered in a separate article here.
There are also some differences in time limits where a notifiable tax avoidance scheme has been used.
Offshore matters / Offshore transfers
The Finance Act 2019 further extended HMRC time limits for making assessments relating to Income Tax, Capital Gains Tax and Inheritance Tax, relating to offshore matters or offshore transfers.
The normal four-year and six-year time limits referred to above were extended to 12 years.
Establishing behaviour and understanding the appropriate HMRC time limits can be complex but is very important in any tax enquiry or disclosure.
Failing to argue your case properly might unnecessarily open many additional years of liability.
If you need help with assessing HMRC time limits, please get in touch.
You can get in touch with our friendly and experienced team on: 0203 675 8122 or email jeremy.johnson@intaxltd.com.
inTAX is a specialist tax disputes firm. We deal with disclosures, investigations, and tax enquiries of all descriptions, including COP9, fraud investigations, VAT fraud, tax avoidance, let property disclosures and tribunal appeals.
However, we do not just deal with the serious end of tax investigations. We are also happy to handle smaller enquiries, disputes and problems that can be equally as worrying for our clients.
