I had an SDLT (Option) advised by CDC Corporate in Oct 2011. HMRC queried it with CDC Corporate and according to communications agreed in a letter dated 12th April 2012 acknowledged there was a land transaction filed. HMRC then queried the use of SDLT on 11th Sept 2015, which CDC Corporate responded to. I now have a letter dated 31st May 2018 saying I have until 28th July 2018 to settle the outstanding Stamp Duty. Does statute of limitations not apply at some point?
Andrew, from what you say it sounds as though HMRC were in time to make a “discovery” assessment in September 2015 and HMRC are now seeking to pressure you into settling the matter. The option scheme is now on their radar and it is regrettable that they allow things to drag on for so long in silence and then pop up out of the blue with a request for payment. This is by no means unusual. Without sight of the relevant communications it is difficult to be sure but to answer your question it doesn’t look as though HMRC are time-barred.