80 Offshore matters or transfers: income tax and capital gains tax
Finance Act 2019 (2019 c 1) | Legislation

Part 4 Administration and Enforcement

Time limits for assessments etc

80  Offshore matters or transfers: income tax and capital gains tax

(1)     TMA 1970 is amended as follows.

(2)     After section 36 insert—

“36A Loss of tax involving offshore matter or offshore transfer

(1)     This section applies in a case involving a loss of income tax or capital gains tax, where—

(a)     the lost tax involves an offshore matter, or

(b)     the lost tax involves an offshore transfer which makes the lost tax significantly harder to identify.

(2)     An assessment on a person (“the taxpayer”) may be made at any time not more than 12 years after the end of the year of assessment to which the lost tax relates.

This is subject to section 36(1A) above and any other provision of the Taxes Acts allowing a longer period.

(3)     Lost income tax or capital gains tax “involves an offshore matter” if it is charged on or by reference to—

(a)     income arising from a source in a territory outside the United Kingdom,

(b)

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