13 March 2019
Patricia Mock, tax director at Deloitte, comments on expected review on extended time limits legislation:
“Extended time limits of 12 years for offshore non-compliance within the scope of income tax, capital gains tax and inheritance tax were introduced in the Finance Act 2019 and can apply to tax years as early as 2013/14 if careless behaviour applied. Following some comment that these rules could mean a long period of uncertainty for taxpayers, even if their affairs were in order, the legislation included a requirement for a government review comparing the new time limits for recovery of offshore tax with other time limits in force.
“Whilst the Spring Statement documentation does include reviews on other matters included in the Finance Act, this review has not been published today but will be published by 30 March 2019. Any further review of these differing time limits and their practical implication will be useful. The review will include comment on the rationale for the charge on disguised remuneration - the loan charge - which was enacted in the Finance (No 2) Act 2017, and its impacts.”
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