What are the standard and extended time limits for WRA assessments under section 59?

The standard time limit for a WRA assessment is 4 years from the relevant date. Where the taxpayer or a related person acted carelessly, the limit extends to 6 years. If the behaviour was deliberate, the Welsh Revenue Authority has up to 20 years from the relevant date to issue an assessment.

What is the time limit for recovering an excessive tax repayment under section 59?

An assessment to recover an excessive tax repayment is always in time if made within 12 months of the date the repayment was actually made. This 12-month rule operates as a separate safety net for the WRA, independent of the standard 4-year, 6-year, or 20-year time limits.

What time limits apply to WRA assessments when a taxpayer has died?

When a taxpayer has died, any WRA assessment on the personal representatives must be made within 4 years of the date of death. Additionally, no assessment may be made in respect of a relevant date that falls more than 6 years before the date of death, providing a backstop limit.

How can a taxpayer challenge a WRA assessment on the grounds that it was issued outside the time limit?

A taxpayer cannot raise a time limit objection informally or as a standalone complaint. The only way to challenge the timeliness of a WRA assessment is through the formal review or appeal process that applies to the assessment itself, as prescribed under the Tax Collection and Management (Wales) Act 2016.

Tax Collection and Management (Wales) Act 2016 section 59

Time limits for WRA assessments

Section 59 sets out the time limits within which the Welsh Revenue Authority (WRA) must make tax assessments, with longer periods allowed where carelessness or deliberate behaviour is involved.

The standard time limit for a WRA assessment for loss of tax, excessive repayment, or incorrect tax credit is 4 years from the relevant date, extending to 6 years where the taxpayer or a related person acted carelessly, and up to 20 years where the behaviour was deliberate.
An assessment to recover an excessive tax repayment is always in time if made within 12 months of the repayment; for unpaid tax credit amounts, the time limit is 12 months from either the payment deadline set by WRA or the date WRA became aware the amount was due.
Where the taxpayer has died, any assessment on the personal representatives must be made within 4 years of the date of death, and no assessment may relate to a relevant date more than 6 years before the date of death.
Any challenge to a WRA assessment on the grounds that the time limit has expired can only be raised through a formal review of, or appeal against, the assessment.

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