Revenue Note for Guidance
Proceedings for the recovery of a penalty may be instituted despite the fact that the amount of income tax or corporation tax by reference to which such penalty is to be calculated has not been finally ascertained. Where the Court is of the opinion that the penalty is recoverable, it may suspend the giving of a judgment or the making an order for payment of that penalty until such time as the amount of tax due is finally ascertained.
Relevant Date: Finance Act 2019