SDLTM84290 - Compliance: Assessments and Revenue Determinations

Time limits for assessments FA03/SCH10/PARA31

The general rule is that no assessment may be made more than 6 years after the effective date of the transaction to which it relates but in cases of fraud or negligence this is extended to 21 years.

If the purchaser has died, assessments must be made within 3 years of the date of death and can only cover transactions within the 6 years prior to death.

An assessment to recover excessive repayment of tax is not out of time

  • if there is an open enquiry into the relevant land transaction return
  • in any case, if it is made within 1 year after the relevant repayment was made

Any objection to the making of an assessment on the grounds that the time limit for making it has expired can only be made on an appeal against the assessment.