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HMRC internal manual

Compliance Handbook

Offshore matters: penalties for enablers of offshore tax evasion or non-compliance: how to process the penalty assessment

Where a person is liable to a penalty HMRC must

  • assess the penalty,
  • notify the person, and
  • state in the notice the specific tax period in respect of which the penalty is assessed. This will usually be the tax year in which the underlying offence occurred.

A penalty must be paid within 30 days of the penalty being issued.

The penalty assessment is enforceable in the same way as an assessment to tax.

The penalty assessment notice also has a section explaining the appeal rights, obligations and deadlines.

Time limit for penalty assessments

A penalty assessment must be made within two years of the date HMRC became aware that conditions A and B have been met, see CH124400 (FA16/Sch20/Para11). In practice you should issue the penalty assessment at the earliest opportunity.

For further details on processing penalties and penalty assessments, see CH403050.

FA16/Sch20/Para10