Part 2Unauthorised payments
Chapter 3Administration
Recovery of overpayments
12.—(1) Where an officer of HMRC considers that an amount was not properly recoverable as an excess amount, either wholly or partially, that amount may be assessed and recovered under this regulation as if it were unpaid tax.
(2) An assessment under this regulation must be made on or before the date four years after the day on which a return was made in respect of the excess amount.