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Careless behaviour time limit

From 1 April 2010 the normal four-year time limit for making an assessment to income tax and capital gains tax or corporation tax (see A4.320) is extended to six years from the end of the tax year or accounting period where the case involves the carelessness of the taxpayer, their agent or a related person¹.

See A4.326 for the impact on this time limit where the assessment relates to a disposal made under contract where completion is delayed². See A4.325A for the time limit where the loss of tax relates to an 'offshore matter' or 'offshore transfer'.

A loss of tax is brought about carelessly by a person if they fail to take reasonable care to avoid bringing about the loss or situation. In particular they are careless where information is provided to HMRC by a person who later discovers that the information is inaccurate but fails to take reasonable steps to inform the tax authorities of the inaccuracy³.

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