SCHEDULES
SCHEDULE 19Large businesses: tax strategies and sanctions
PART 2Publication of tax strategies
Assessment of penalties
29
1
Where a person becomes liable to a penalty—
a
HMRC may assess the penalty, and
b
if they do so, HMRC must notify the person of the assessment.
2
An assessment of a penalty may not be made—
a
more than 6 months after the failure first comes to the attention of an officer of Revenue and Customs, or
b
more than 6 years after the end of the financial year in which the tax strategy to which the failure relates was (or was originally) required to be published.