{
  "url": "https://openlegislation.uk/finance-act-2022/section-87",
  "json_url": "https://openlegislation.uk/finance-act-2022/section-87.json",
  "legislation": "ukpga/2022/3",
  "legislation_title": "Finance Act 2022",
  "legislation_url": "https://openlegislation.uk/finance-act-2022",
  "path": "section/87",
  "kind": "section",
  "number": "87",
  "heading": "Freezing orders: England and Wales",
  "text": "(1) Subsection (2) applies where —\n(a) an application is made on behalf of HMRC to a court in England and Wales for a freezing order in relation to a relevant penalty (see section 90) before the penalty is determined, and\n(b) the court considering the application is satisfied that HMRC have a good arguable case in relation to the penalty and—\n(i) have commenced proceedings before the First-tier Tribunal in relation to it, or\n(ii) intend to commence proceedings before the First-tier Tribunal in relation to it within the initial period.\n(2) The court is to determine the application as if it were being made immediately after the First-tier Tribunal had determined the penalty on the basis sought, or to be sought, by HMRC.\n(3) A freezing order granted by virtue of subsection (2) may not take effect unless HMRC commence proceedings before the First-tier Tribunal in relation to the penalty before the end of the initial period (whether before or after the making of the application for the order).\n(4) In this section, a “freezing order” is an order granted in accordance with rule 25.1(1)(f) of the Civil Procedure Rules.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2022/3/section/87",
    "retrieved_at": "2026-10-29T08:57:50.927298+00:00",
    "licence": "OGL-UK-3.0",
    "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."
  }
}