I beg to move amendment No. 248, in schedule 24, page 262, line 19, leave out ‘30’ and insert ‘60’.

Interesting to finish my career shadowing the Treasury with a sex change. Paragraph 2 of schedule 24 is designed to give HMRC the power to penalise a taxpayer if they have

“failed to take reasonable steps to notify them, within the period of 30 days beginning with the date of the assessment, that it is an under-assessment.”

Our amendment is simply designed to increase the period that a taxpayer has to 60 days. The amendment is necessary because, in the words of the ICAEW,

“The 30 day time limit looks unreasonable, particularly given that the 30 days starts from the date that is on the assessment rather than the date it is received by the taxpayer. We think it would be more reasonable to give a 60 day period.”

The point about the time that it takes to receive the assessment after the 30-day clock has already started ticking seems valid, not least because the taxpayer could be on holiday when the assessment arrives. Similarly, any disruption to the postal service, say as a result of industrial action, could eat into a good part of the 30-day period. That seems pertinent in light of the stand-off between Royal Mail and the trade unions, which could lead to the first national postal strike in many years.

In addition, the assessment in the case of a complicated return might take some time to check, and the taxpayer might be reliant on their adviser to do it for them and to communicate the information to them. That can all take time. I would be grateful if the Minister could clarify whether the clause is intended to be used in all cases of HMRC errors that lead to an underassessment or, as I believe has been suggested to some members of the professions, it is likely to be used in practice only in cases of default assessments issued in the absence of a completed tax return. Subject to the answer to my question, we believe that it would be reasonable to extend the period that the taxpayer has to receive and check their assessment from 30 to 60 days. I commend the amendment to the Committee.