In its response to the consultation “Extension of Offshore Time limits”, the Northern Ireland Tax Committee argues that the Republic of Ireland should be excluded from the definition of offshore where non-deliberate behaviour is involved, given its close promixity to taxpayers in Northern Ireland.

The Committee also argues against extending the time limits for discovery and careless behaviour further as these have already been extended as a result of the requirement to correct legislation.

In its submission the Committee also makes the following key recommendations:

• HMRC should delay the introduction of extended time limits until at least April 2021 and should assess the case for their introduction at that point only;
• If time limits are extended, penalties should not apply to additional years or alternatively lower penalties should apply to any additional years in scope; and
• The commencement date for any extension to the assessment time limits should only catch offshore non-deliberate behaviour occurring on or after the commencement date.

The Committee’s response can be read in full on here.