38(1)Any amount due by way of multinational top-up tax liability is recoverable as a debt due to the Crown.
(2)“Multinational top-up tax liability”, in relation to a multinational group for an accounting period, means—
(a)a liability of any person who was a member of the group in the period to multinational top-up tax in respect of the period;
(b)a liability of a person to a penalty referred to in paragraph 40 for anything done (or not done) in respect of the period.