Sch 10 para 4 Time limits on penalty assessments
(1) Subject to sub-paragraphs (2) and (3) below, an assessment under paragraph 2 above to a civil penalty shall not be made more than 4 years after the conduct to which the penalty relates. (2) An assessment of a person to a civil penalty in a case involving a loss of aggregates levy— (a) brought about deliberately by the person (or by another person acting on that person's behalf), or (b) attributable to a failure by the person to comply with an obligation under section 24(2) or paragraph 1 of Schedule 4, may be made at any time not more than 20 years after the conduct to which the penalty relates (subject to sub-paragraph (3)). (2A) In sub-paragraph (2)(a) the reference to a loss brought about deliberately by the person includes a loss brought about as a result of a deliberate inaccuracy in a document given to Her Majesty's Revenue and Customs by or on behalf of that person. (3) Where, after a person’s death, the Commissioners propose to assess an amount of a civil penalty due by reason of some conduct of the deceased— (a) the assessment shall not be made more than 4 years after the death; ... (b) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .