SCHEDULES
SCHEDULE 25Penalties for deliberately withholding information
PART 2Liability to a penalty
Supplementary assessments
I113
1
A supplementary assessment may be made in respect of a penalty under this Schedule if an earlier assessment—
a
is based on a liability to tax that would have been shown in a return, and that liability is found by HMRC to be an underestimate, or
b
is based on a liability to tax that is found by HMRC to be insufficient.
2
Sub-paragraph (3) applies if an assessment in respect of a penalty—
a
is based on a liability to tax that would have been shown in a return, and that liability is found by HMRC to be an overestimate, or
b
is based on a liability to tax that is found by HMRC to be excessive.
3
HMRC may by notice to the person amend the assessment so that it is based upon the correct amount.
4
An amendment under sub-paragraph (3)—
a
does not affect when the penalty must be paid;
b
may be made after the last day on which the assessment in question could have been made under paragraph 14.