Revenue Note for Guidance
This section provides that assessments and amendments of assessments on a person may be made at any time where a Revenue officer has reasonable grounds for believing that there is fraud or neglect involved in relation to tax due for the chargeable period
“Neglect” is defined as failing to give notice, make a return, or produce information required under the Acts.
A person will not be guilty of neglect if they acted on their obligations without delay after being requested to do so by Revenue, or, if they had failed to act on them because of a valid excuse but acted once that excuse had expired.
Notwithstanding section 959AA (time limits for assessments on chargeable persons) and section 959AB (time limits for assessments on persons other than chargeable persons) Revenue may make a Revenue assessment at any time where they suspect fraud or neglect.
Assessments made under this section are for the amount that ought to be charged on the person in the Revenue officer’s best judgement.
This section also provides that Revenue may amend a Revenue assessment or a self assessment in similar circumstances.
Relevant Date: Finance Act 2021