12 months to open an enquiry into a tax return (such enquiry to be left open as long as HMRC reasonably need to conduct enquiries).
In other cases: ...
6 years if the taxpayer's error is down to carelessness; or
20 years if the taxpayer's error is down to fraud ("deliberate conduct").
My principal objection to the loan charge ...
- For those taxpayers where HMRC have been too slow to use their existing statutory powers, it simply gives HMRC a second chance to remedy their previous oversights.
- ...