Revenue eBrief No. 048/24
20 February 2024
Part 41A-05-04 Full self-assessment Time limits for making enquiries and making or amending assessments
Tax and Duty Manual 41A-05-04 (Full self-assessment: Time limits for making enquiries and making or amending assessments) has been updated in Paragraph 4 to refer to an amendment in Finance Act 2022 to section 959AA(2A) Taxes Consolidation Act 1997, which explicitly provides that assessments may be amended outside of the normal four-year time limit as a result of a Mutual Agreement Procedure (MAP) determination. The TDM also outlines that tax returns may be amended outside of the four-year time limit to account for the knock on effects of a MAP or correlative adjustment, even if the company whose return is amended was not directly a party to the MAP or correlative adjustment.
In addition, Paragraph 3, which outlines exceptions to the four-year limit for making enquiries, and Paragraph 4, which outlines the time periods for making or amending assessments, have been amended for ease of understanding.