Under the UK tax law system two categories of offences are recognised, namely: minor
offences, such as unintentional late tax payment, which may be subject to civil penalties;
and major or severe offences, such as negligently or fraudulently making an under
payment, in which criminal procedure and charges may be involved.41 The definition
and categorisation of these different types of surcharges will be addressed in this
section, beginning with criminal penalties, and then administrative tax penalties, and
interests.