HMRC

How far can HMRC go back in terms of years for APN's Accelerated payment Notices

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Looking for any help on Discovery provisons - HMRC

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By johngroganjga
06th Dec 2017 12:14

Unless I am missing something, for there to be an APN there must be an open enquiry. An enquiry can remain open for as long as it takes to reach a conclusion. So there is literally no limit to the number of years APNs can go back for. But there are indeed time limits for opening enquiries, barring discovery. Is that your question.

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By Justin Bryant
06th Dec 2017 15:54

Someone was asking about time limits on HMRC enquires here recently and Article 6 HRA 1998. There was the case in the link below, but it was not fully argued properly there, possibly coz the case law has since developed.

http://www.bailii.org/ew/cases/EWHC/Ch/2007/1181.html

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