At the Autumn Budget 2017, the government announced that the assessment time limit for non-deliberate offshore 
tax non-compliance will be increased to at least twelve years after the end of the relevant tax year or relevant period.
Where there is deliberate behaviour, the current time limit of twenty years will remain.
The government’s logic for making these changes is that it is right and fair that everyone pays all the tax they owe, including on offshore income, gains and chargeable transfers. This extension of time limits for offshore cases reflects the fact that it can take much longer for HMRC to establish the facts concerning offshore transactions, particularly when a complex offshore structure is involved.
HMRC officers require additional time to address situations where the current assessment time limits of four and six years are not sufficient to establish the facts and determine and assess the amount of tax due.
The current consultation which was launched mid-February sets out the design principles for the new legislation, including the scope, commencement and transitional provisions, and invites comments on certain aspects of the design.
A copy of the consultation document upon which comments should be made can be found on the .Gov website.
The Bedrock team are experienced in helping with offshore disclosures to HMRC, read more about how we have assisted a client through the case study here.
