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(1)Where an assessment has been made for the purpose of making good to the Crown a loss of tax wholly or partly attributable to the fraud, wilful default or neglect of any person, the tax charged by the assessment, or as the case may be such part thereof as corresponds to the part so attributable, shall carry interest at the prescribed rate from the date on which the tax ought to have been paid until payment.
(2)This section shall not apply in relation to tax under Schedule 9 to the principal Act.
(3)Tax carrying interest under this section shall not carry interest under section 86 above.
(4)The Board may at their discretion mitigate (whether before or after judgment) any interest due under this section and may stay or compound any proceedings for the recovery thereof.
(5)For the purposes of this section the date when tax ought to have been paid shall be taken to be—
(a)in the case of income tax, 1st January in the year of assessment for which the tax is charged, but subject to paragraphs (b) and (c) below,
(b)in the case of one-half of any income tax specified in section 4(2) of the principal Act, the following 1st July,
(c)in the case of surtax, 1st January in the year of assessment next following the year for which the tax is charged,
(d)in the case of capital gains tax, 6th July in the year of assessment next following the year for which the tax is charged,
(e)in the case of corporation tax, the date nine months from the end of the accounting period for which the tax is charged or, where section 244(1) of the principal Act applies, at the end of the interval mentioned in that subsection (without the alternative of one month from the making of the assessment).
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