HMRC asking for 12 year window to raise assessments involving offshore transactions

[Loan Ranger]

No - not a loan based scheme. And there has been NO communication about any liability.

Once HMRC have opened an enquiry, there is no statutory time limit for issuing a closure notice.

I wouldn't have thought any extension to the assessment window would affect you because HMRC only raise an assessment where they've not previously opened an enquiry.

It's either:

s9a enquiry then s28 (1) & (2) closure notice

OR

s29 discovery assessment