Time Limit on Appeal Decisions (Are there any?)

[ukcommando]

Unfortunately, once HMRC open an investigation (enquiry/assessment) into a year, there is no time limit for them to conclude it. They can sit on an appeal indefinitely.

Rather as I suspected, but appalling all the same, especially when there is no communication whatsoever from them in the meantime, even if only to say that it's on hold pending ongoing legal test cases, etc.. Given that there are time limits on how they act when, for example, a completed tax return is submitted, it is extremely poor that there are apparently no controls on appeals. Can you imagine how it would appear if they decided to finally act on an appeal after 20, 30, 40 or more years (especially with total silence in between)?

[woody1]

Unfortunately, once HMRC open an investigation (enquiry/assessment) into a year, there is no time limit for them to conclude it. They can sit on an appeal indefinitely.

[ukcommando]

I had a determination issued in 2014 about an EBT in 2010, which was then followed up by an APN in the months after. At the time, I engaged a consultant who appealed the APN, and I then received a letter withdrawing it which would have been no later than 2016.

Recently I received a letter stating that they have now decided that the determination is valid. Interestingly, they have reduced the amount due by upwards of £16k as they admit an error in the original determination (Basically the original demand was for 40% on the whole loan).

My question is, are there any time limits whatsoever on the appeals process? I have heard absolutely nothing, zilch, from them for 8 years. During that period, I made full settlement on some later, non EBT, loans that were subject to the Loans Charge, and in my mind had put the whole sorry mess to bed. So it was a shock to receive this letter.

I am not holding out any serious hope of it being time barred, but given that normal debt has a time limit of (I believe) six years for legal pursuit to be actioned, I am wondering if HMRC are subject to any time limits at all? Especially as they have limits on initiating claims etc.. All info appreciated.