666. Nature of and time limit for proceedings.

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