SCHEDULE 36Information and inspection powers
Part 7Penalties
Assessment of ... penalty
46
(1)
(a)
F3HMRC may assess the penalty, and
(b)
F4if they do so, they must notify the person.
(2)
An assessment of a penalty under paragraph 39 or 40 must be made F5within the period of 12 months beginning with the date on which the person became liable to the penalty, subject to sub-paragraph (3).
F6(3)
In a case involving an information notice against which a person may appeal, an assessment of a penalty under paragraph 39 or 40 must be made within the period of 12 months beginning with the latest of the following—
(a)
the date on which the person became liable to the penalty,
(b)
the end of the period in which notice of an appeal against the information notice could have been given, and
(c)
if notice of such an appeal is given, the date on which the appeal is determined or withdrawn.
(4)
An assessment of a penalty under paragraph 40A must be made—
(a)
within the period of 12 months beginning with the date on which the inaccuracy first came to the attention of an officer of Revenue and Customs, and
(b)
within the period of 6 years beginning with the date on which the person became liable to the penalty.