CH192410 - Penalty reform - penalties for failing to file VAT returns by the due date for periods from 1 January 2023: other penalty issues: double jeopardy
NB: “These rules currently only apply to VAT for VAT periods starting on or after 1 January 2023. These rules will come into force for other tax regimes at a future date. You must check the date from which these rules apply for the tax or duty you are dealing with”
A taxable person is not liable to a penalty point or financial penalty in respect of a failure for which the taxable person has been convicted of a criminal offence.
FA2021 SCH 24 para 20