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.