6(1)The Commissioners may not give a secondary liability and assessment notice to R in respect of an amount of plastic packaging tax after the end of the period of 2 years beginning with—
(a)the day after the last day of the accounting period by reference to which P was liable to pay the amount, or, if later,
(b)the day on which a court or tribunal finally determines that P is liable to pay the amount.
(2)But in a case involving a loss of tax brought about deliberately by R or P (whether acting alone or with another person) sub-paragraph (1) has effect as if the reference to 2 years were to 20 years.