Paragraph 26
(1)
Paragraphs 27 to 33 apply in relation to the liability of any person to a penalty under this Part and, accordingly, in those paragraphs—
“failure”, in relation to a liability for a penalty, means a failure which could give rise to that liability,
“liability to a penalty” means a liability under paragraph 18, 21 or 24 (including paragraph 24 as applied to a qualifying UK partnership), and
“penalty” means a penalty under any of those paragraphs.
(2)
In those paragraphs “tribunal” means the First-tier Tribunal or, where determined by or under the Tribunal Procedure Rules, the Upper Tribunal.