Section 233

The institution of proceedings or the imposition of a penalty, special penalty, fine or term of imprisonment under this Part shall not relieve any natural person or Constituent

Entity from liability for the payment of any Domestic

Top-up Tax or Multinational Top-up Tax (or any penalty deemed under this Part to be tax payable) or any debt or other sum for which the natural person or Constituent Entity is or may be liable or from liability to make any return which the natural person or Constituent Entity is required by this Part to make.