SCHEDULES
SCHEDULE 20Penalties for enablers of offshore tax evasion or non-compliance
PART 1Liability for penalty
Procedure for assessing penalty, etc
I110
1
Where a person is found liable for a penalty under paragraph 1 HMRC must—
a
assess the penalty,
b
notify the person, and
c
state in the notice the period in respect of which the penalty is assessed.
2
A penalty must be paid before the end of the period of 30 days beginning with the day on which notification of the penalty is issued.
3
An assessment of a penalty—
a
is to be treated for procedural purposes in the same way as an assessment to tax (except in respect of a matter expressly provided for by this Schedule), and
b
may be enforced as if it were an assessment to tax.
4
A supplementary assessment may be made in respect of a penalty if an earlier assessment operated by reference to an underestimate of the liability to tax that would have been shown in a return.
5
Sub-paragraph (6) applies if—
a
an assessment in respect of a penalty is based on a liability to tax that would have been shown on a return, and
b
that liability is found by HMRC to have been excessive.
6
HMRC may amend the assessment so that it is based upon the correct amount.
7
But an amendment under sub-paragraph (6)—
a
does not affect when the penalty must be paid, and
b
may be made after the last day on which the assessment in question could have been made under paragraph 11.