No proceedings for an offence under section 227, 229, 230
or 231 shall be instituted more than twelve years after the offence was committed.
Any natural person or Constituent Entity who aids, abets or incites another natural person or Constituent Entity to commit an offence under section 227, 229, 230 or 231
Constituent Entity
“Constituent Entity” means— (a) any Entity that is included in a Group; or (b) any Permanent Establishment of a Main Entity that is within paragraph (a) and which is treated as separate from the Main Entity and any other Permanent Establishment of that Main Entity, but does not include an Excluded Entity;
shall be deemed to have committed the same offence and shall be liable to the same penalty.
Domestic Top-up Tax and Multinational Top-up Tax, etc., payable notwithstanding institution of proceedings
Domestic Top-up Tax
“Domestic Top-up Tax” means tax as provided under section 159;