Taxes Management Act 1970 section 43C

Consequential claims etc.

Section 43C deals with the time limits and rules that apply when HMRC amends a tax return following an enquiry, and the consequential claims that may arise from such amendments.

• When HMRC amends a return after an enquiry to recover tax lost through careless or deliberate behaviour, the extended time limits for careless or deliberate conduct apply to that amendment as if it were a discovery assessment.
• When HMRC amends a return after an enquiry for any other reason, the standard time limits and rules on further assessments and claims apply to that amendment as if it were a discovery assessment.
• Any references to an "assessment" in the relevant time limit and claims provisions should be read as references to the amendment of the return.
• Where an assessment is needed to give effect to or as a result of allowing a consequential claim, that assessment is not out of time provided it is made within one year of the claim being finally determined, meaning it can no longer be varied on appeal or otherwise.