19(1)An assessment of a penalty under any paragraph of this Schedule in respect of any amount must be made on or before the later of date A and (where it applies) date B.U.K.
(2)Date A is the last day of the period of 2 years beginning with the filing date.
(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 liability to tax which would have been shown in the return, or
(b)if there is no such assessment, the date on which that liability is ascertained or it is ascertained that the liability is nil.
(4)In sub-paragraph (3)(a) “appeal period” means the period during which—
(a)an appeal could be brought, or
(b)an appeal that has been brought has not been determined or withdrawn.
(5)Sub-paragraph (1) does not apply to a re-assessment under paragraph 24(2)(b).
Commencement Information
I1Sch. 55 para. 19 in force at 1.4.2011 for specified purposes and 6.4.2011 for specified purposes by S.I. 2011/702, art. 2 (with art. 1(2))