I have a client who, although he has always been within self-assessment, has not submitted a tax return since 2007/08.
I am now preparing his returns for the tax years 2008/09 - 2011/12.
In 2008/09, client made a £1,000,000+ gain on the associated disposal of a business asset (land) shortly before the liquidation of his trading company. The gain would ordinarily have qualified for ER and therefore been reduced by 4/9ths but we are unfortunately now outside the time limit for ER claims, which is one year from the filing date of the return for the year in which the gain is made.
My feeling is that the client is stuffed and has just lost £80k but if anyone knows differently or has found HMRC to be lenient when it comes to time limits for claims of this nature, I would be overjoyed to hear their thoughts!