[10A Application of GAAR in relation to penalties]

[10A  Application of GAAR in relation to penalties]

[(1)     For the purposes of this section a penalty under section 212A of the Finance Act 2013 is a “relevant NICs-related penalty” so far as the penalty relates to a tax advantage in respect of relevant contributions.

(2)     A relevant NICs-related penalty may be recovered as if it were an amount of relevant contributions which is due and payable.

(3)     Section 117A of the Social Security Administration Act 1992 or (as the case may be) section 111A of the Social Security Administration (Northern Ireland) Act 1992 (issues arising in proceedings: contributions etc) has effect in relation to proceedings before a court for recovery of a relevant NICs-related penalty as if the assessment of the penalty were a

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