Time limits and treatment of penalties
17.—(1) Proceedings in relation to a penalty under regulation 13(1)(a)(ii) must be commenced, or a determination of a penalty under regulation 13(1)(a)(i) or 13(1)(b) must be made, before the latest of the following dates—
(a)the date 24 months after the date on which the inaccuracy or failure first came to the attention of an officer of Revenue and Customs,
(b)the date six years after the date on which the person became liable to the penalty, and
(c)in the case of a determination of a penalty under regulation 13(1)(b), the date three years after the date of determination of a penalty under regulation 13(1)(a).
(2) A penalty determined under this Part is due and payable at the end of the period of 30 days beginning with the date of determination of the penalty by the First-tier Tribunal or issue of the notice of determination, as the case may be.
(3) A penalty determined under this Part is to be treated for all purposes as if it were tax charged in an assessment and due and payable.