Value Added Tax Act 1994 section Schedule 9A paragraph 4

Time limit on directions

Schedule 9A paragraph 4 sets out the time limits within which HMRC may issue a direction under Schedule 9A, and clarifies how those limits interact with events that occurred before the Schedule came into force.

• A direction must be issued within six years of the later of the relevant event or the date the relevant entitlement arose.
• No direction may be given by reference to a relevant event that occurred on or before 28 November 1995.
• Subject to the six-year and 28 November 1995 cut-offs, a direction may relate to a relevant event that occurred before the Schedule came into force and may require assumptions about periods before 29 November 1995.
• The relevant entitlement is the entitlement by reference to which the conditions in paragraph 1(4) of the Schedule are treated as satisfied for the purposes of the direction.