Commentary on Sections Penalties Section 47: Assessment and enforcement of penalties
205.Section 47 sets out how HMRC may assess and enforce any penalty which a person has become liable to under the Act. HMRC must notify a person if it assesses that they are liable to a penalty.
206.Subsections (2) and (3) impose time limits on HMRC for assessing penalties. An assessment must be made by the earlier of:
	four years from the day the person first became liable to the penalty (or, in cases of dishonesty, 20 years from that time); and
	12 months after the day HMRC first believed, or first had reasonable grounds to believe, that the person was liable to the penalty.
207.A person must pay a penalty as a result of an assessment under this section:
	within 30 days, if they do not apply for a review;
	within 30 days of the end of the review, if they do not appeal against its conclusion; and
	if the person has appealed against the penalty, on the day on which the appeal is determined or withdrawn.
208.Subsection (5) provides that any penalty imposed under the Act can be enforced as if it were an assessment of income tax which is due.