2

An assessment in a case involving a loss of tax brought about carelessly by the company (or a related person) may be made at any time not more than 6 years after the end of the accounting period to which it relates (subject to sub-paragraph (2A) and to any other provision of the Taxes Acts allowing a longer period).

2A

An assessment in a case involving a loss of tax—

a

brought about deliberately by the company (or a related person),

b

attributable to a failure by the company to comply with an obligation under paragraph 2, or

c

attributable to arrangements in respect of which the company has failed to comply with an obligation under section 309, 310 or 313 of the Finance Act 2004 (obligation of parties to tax avoidance schemes to provide information to Her Majesty's Revenue and Customs),

may be made at any time not more than 20 years after the end of the accounting period to which it relates (subject to any provision of the Taxes Acts allowing a longer period).

2B

In this paragraph “related person”, in relation to a company, means—

a

a person acting on behalf of the company, or

b

a person who was a partner of the company at the relevant time.