Recovering penalties, surcharges and interest

For the purposes of the rules relating to:

taking control of goods (distraint in Northern Ireland) (see ¶188-095);

poinding (see ¶188-145);

court proceedings (see ¶188-120¶188-145); and

the Crown Proceedings Act 1947, s. 35(2) (rules of court, etc.: restriction of set-off or counterclaim where proceedings, or set-off or counterclaim, relate to tax),

the following are treated as tax (TMA 1970, s. 69):

(a)penalties imposed under TMA 1970, Pt. II, VA and X (i.e. TMA 1970, s. 712B, 59A59E and 93106), or FA 1998, Sch. 18,

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