SCHEDULES
SCHEDULE 26Penalties for failure to pay tax
PART 3Supplementary provision
18Time limit for assessments
1
An assessment of a penalty under this Schedule in respect of any amount must be made on or before the later of date A and (where it applies) date B.
2
Date A is the last day of the period of 2 years beginning with the date specified in or for the purposes of column 3 of the relevant table in paragraph 1 (that is to say, the last date on which payment may be made without incurring a penalty).
3
Date B is the last day of the period of 12 months beginning with—
a
the end of the appeal period for the assessment of the amount of tax in respect of which the penalty is assessed, or
b
if there is no such assessment, the date on which that amount of tax is ascertained.
4
In sub-paragraph (3)(a) “appeal period” means the period during which—
a
an appeal could be brought (ignoring any possibility of an appeal out of time), or
b
an appeal that has been brought has not been determined or withdrawn.