Commentary

I11.705 Proceedings for recovery of penalties

IHT, trusts and estates

I11.705 Proceedings for recovery of penalties

I11.705 Proceedings for recovery of penalties

Where, under the general rule, proceedings for the recovery of a penalty are commenced by the Board (or the Advocate General for Scotland) they may be commenced either before the First-tier Tribunal or in the High Court or the Court of Session1. Such proceedings, if brought in the High Court, are deemed to be civil proceedings by the Crown within the meaning of the Crown Proceedings Act 1947 Part II (ie sections 13 to 23) or, as the case may be, that Part as for the time being in force in Northern Ireland2.

Where proceedings

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