SolvedCH26860 | Information & Inspection Powers: Penalties: Penalty assessments: When to issue a penalty assessment
From HM Revenue & Customs · Compliance Handbook
Normally you should issue the penalty assessment to the person as soon as possible (see CH26760) after the date
specified on the information notice for producing the documents or providing the information has passed and the information or documents have not been supplied, or
the deliberate obstruction occurs, or
you decide to impose daily penalties, or
the Upper Tribunal determined an amount of tax-related penalty, or
an inaccuracy in information provided or documents produced in response to the notice comes to your attention.
However, you must issue a penalty assessment within the following time limits:
For initial, daily and increased daily penalties you must issue the penalty assessment in the 12 months after the latest of
the end of the period during which the person can appeal where there is a right of appeal against the information notice, see CH24320, or
the date on which the appeal is finally decided or the person withdraws it when a person has appealed against the information notice, or
the date on which the person became liable to the penalty in any other case.
For tax-related penalties you must make the application to the Upper Tribunal within the 12 month period described above.
For penalties for an inaccuracy in information provided or a document produced in response to an information notice you must issue a penalty assessment within
12 months of the date on which the inaccuracy first came to the attention of an officer of Revenue and Customs and
6 years of the date on which the person became liable to the penalty.