Regulation 12 Transitional provision
In any case under regulation 13(2) or 18(2) of the Stamp Duty Reserve Tax Regulations 1986 where—
(a)
a relevant transaction or surrender took place before 1st April 2011; and
(b)
an underpayment or repayment was brought about by fraudulent or negligent conduct by or on behalf of any person;
the period in which a determination may be made is the earlier of the period of 6 years beginning when the fraudulent or negligent conduct comes to the knowledge of Her Majesty’s Revenue and Customs or the period of 20 years provided in regulation 13(3) or 18(3A).