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For 2013/14 onwards for loss of tax brought about carelessly, and for 2015/16 onwards in all other cases¹, extended time limits under TMA 1970, s 36A for making an assessment to income tax and capital gains tax apply where the loss of tax involves either an offshore matter, or an offshore transfer which makes the lost tax significantly harder to identify². This includes cases where, as a result, HMRC was significantly less likely to become aware of the lost tax or was likely to become aware of it at a significantly later time³. See also 'Case law on extended time limits involving offshore matters or offshore transfers' below.

Where TMA 1970, s 36A applies, the assessment can be made up to 12 years after the tax year to which the loss relates, unless TMA 1970, s 36(1A) (see A4.325) or any other provision provides for a longer time limit⁴.

Lost tax involves an offshore matter if it relates to⁵: