21 Decisions, appeals, mitigation and recovery

21  Decisions, appeals, mitigation and recovery

(1)     It is for the Inland Revenue to impose a penalty under section 20.

(2)     If the Inland Revenue decide to impose such a penalty the decision must (subject to the permitted maximum) set it at such amount as, in their opinion, is appropriate.

(3)     A decision to impose such a penalty may not be made after the end of the period of six years beginning with the date on which the penalty was incurred or began to be incurred.

(4)     The Inland Revenue must give notice of such a decision to the person on whom the penalty is imposed.

(5)     The notice must state the date on which it is given and give

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