{
  "url": "https://openlegislation.uk/finance-act-2009/schedule-51/paragraph-36",
  "json_url": "https://openlegislation.uk/finance-act-2009/schedule-51/paragraph-36.json",
  "legislation": "ukpga/2009/10",
  "legislation_title": "Finance Act 2009",
  "legislation_url": "https://openlegislation.uk/finance-act-2009",
  "path": "schedule/51/paragraph/36",
  "kind": "paragraph",
  "number": "36",
  "heading": null,
  "text": "(1) Paragraph 108 (time limits on penalty assessments) is amended as follows.\n(2) In sub-paragraph (1), for “three years” substitute “ 4 years ”.\n(3) For sub-paragraph (2) substitute—\n“(2) An assessment of a person to a penalty in a case involving a loss of levy—\n(a) brought about deliberately by the person (or by another person acting on that person's behalf), or\n(b) attributable to a failure by the person to comply with an obligation under paragraph 53 or 55,\nmay be made at any time not more than 20 years after the conduct to which the penalty relates (subject to sub-paragraph (3)).\n(2A) In sub-paragraph (2)(a) the reference to a loss brought about deliberately by the person includes a loss brought about as a result of a deliberate inaccuracy in a document given to Her Majesty's Revenue and Customs by or on behalf of that person.”\n(4) In sub-paragraph (3)—\n(a) in paragraph (a), for “three years” substitute “ 4 years ”, and\n(b) omit paragraph (b) (and the “and” before it).",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "I",
      "label": "I1",
      "text": "Sch. 51 para. 36 in force at 1.4.2010 for the purposes of the amendments made by that paragraph by S.I. 2010/867, art. 2(1) (with arts. 21-23)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2009/10/schedule/51/paragraph/36",
    "retrieved_at": "2026-10-29T09:11:08.872832+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}