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Section 69D(3)

VATA 1994
Value Added Tax Act 1994 · United Kingdom

A decision notice— may not be given before the amount of the penalty due from the company has been assessed (but it may be given immediately after that has happened), and may not be given more than two years after the denial decision relevant to that penalty was issued.

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Source: legislation.gov.uk · retrieved 2026-07-28