Proceedings for the recovery of penalties are not criminal proceedings1, nor it seems are they proceedings in tort2.
Where the amount of a penalty is to be ascertained by reference to tax payable by a person for any period, the penalty may be determined by an officer of Revenue and Customs, or proceedings for the penalty may be commenced before the tribunal or a court:
(1) at any time within six years after the date on which the penalty was incurred; or
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