(1) An assessment of a penalty under this Chapter . . . must be made on or before the later of date A and (where it applies) date B.
(2) Date A is the last day of the period of 2 years beginning with—
(a) in the case of failure to make a tax return, the filing date, . . .
(b) in the case of failure to pay a devolved tax, the penalty date[,
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