Corporation Tax Act 2010 section 727

Extended time limit for assessment

Section 727 extends the normal time limit for making tax assessments where the effect of a change in company ownership only becomes apparent some years after the change occurs.

• Where provisions in Chapters 2 to 6 depend on circumstances arising after a change in company ownership, HMRC has an extended window in which to raise an assessment.
• The relevant circumstances or events must occur no more than 5 years after the change in ownership for the extended time limit to apply.
• An assessment giving effect to these provisions will be valid if made within 6 years from the date of the relevant circumstances or events (or the latest of them if there are several).
• This ensures HMRC can still act where the tax consequences of a change in ownership only crystallise some time after the change itself.