Self-assessment time limits for making enquiries and amending assessments

Revenue has updated the Tax and Duty Manual regarding full self-assessment time limits for making enquiries and making or amending assessments. Finance Act 2022 amended section 959AA(2A) TCA 1997, which 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 updated manual 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.

The MAP is a means through which competent authorities consult to resolve disputes regarding the application of double taxation conventions.