What do you guys think of this?
https://www.gov.uk/government/consultations/extension-of-offshore-time-limits
In any event, HMRC is able to raise protective assessments up to last 6 tax years from the year in which they inquire into any tax return or when a disclosure is made.
Do you buy their reason below?! I think they are either trying to cover their inefficiency and incompetence or obviously trying to get away with the fact that they are not happy with 6 year limit for offshore matters. 
HMRC is extending the time limit because it can take much longer to establish the facts about offshore transactions, particularly if they involve complex offshore structures. More time is needed to address situations where the current assessment time limits of 4 and 6 years for offshore non-compliance are not long enough to establish the facts, and determine and assess the amount of tax due.
Sameera