(1)No WRA assessment may be made more than 4 years after the relevant date.
(2)But a WRA assessment of a taxpayer in any case involving a situation mentioned in section 54 or 55 brought about carelessly by the taxpayer or a related person may be made up to 6 years after the relevant date.
(3)And a WRA assessment of a taxpayer in any case involving a situation mentioned in section 54 or 55 brought about deliberately by the taxpayer or a related person may be made up to 20 years after the relevant date.
(4)A WRA assessment under section 55 is not out of time if it is made within the period of 12 months beginning with the day on which the repayment in question was made.
(5)If the taxpayer has died—
(a)any WRA assessment on the personal representatives must be made before the end of the period of 4 years beginning with the date of the death, and
(b)a WRA assessment is not to be made in respect of a relevant date more than 6 years before that date.
(6)Any objection to the making of a WRA assessment on the ground that the time limit for making it has expired can only be made on a review of or appeal against the assessment.
(7)In this section—
“related person” (“person cysylltiedig”), in relation to the taxpayer, means—
a person acting on the taxpayer’s behalf, or
a person who was a partner in the same partnership as the taxpayer;
“relevant date” (“dyddiad perthnasol”) means—
if the tax return was made after the filing date, the day on which the tax return was made, or
otherwise, the filing date.