How far can HMRC look back?
In almost all cases where there are liabilities relating to offshore matters, HMRC will have extended time limits in which to raise tax/penalty assessments. However, the tax years relevant to a disclosure are dependent on the underlying ‘behaviour’ that led to the error. The time limits are further extended in cases where HMRC views the errors as deliberate, as opposed to non-deliberate/careless behaviour.
As part of our work, we ensure that all necessary tax periods are reviewed, and further ensure that HMRC has the relevant information to understand why any errors occurred, including the underlying behaviour, helping mitigate any penalty charged, and expediting the process to a correct and fair settlement.