A company which fails to comply with the requirements for notification, making of necessary arrangements for payment of outstanding tax or approval of those arrangements (¶194-600) is liable to a monetary penalty (TMA 1970, s. 109C). That penalty is not to exceed the amount of tax which is payable by the company in respect of ‘periods’ beginning before it commits the failure of compliance and unpaid at that time.

The term ‘periods’ is not defined but is presumably wide enough to include any time period up to the failure to comply which, under any provisions, is a period by reference to which such tax is payable (see ¶194-600).

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