Paragraph 7

In paragraph 18 (assessment), for sub-paragraph (5) substitute—

“(5)

Sub-paragraph (6) applies if—

(a)

an assessment in respect of a penalty is based on a liability to tax that would have been shown in a return, and

(b)

that liability is found by HMRC to be excessive.

(6)

HMRC may by notice to P amend the assessment so that it is based upon the correct amount.

(7)

An amendment under sub-paragraph (6)—

(a)

does not affect when the penalty must be paid;

(b)

may be made after the last day on which the assessment in question could have been made under paragraph 19.”