This section applies to—
(a) penalties imposed under Part 2, 5A or 10 of this Act or Schedule 18 to the Finance Act 1998;
(aa) penalties imposed under Schedule 26 to the Finance Act 2021;
(b) penalties imposed under any paragraph of Schedule 56 to the Finance Act 2009 in respect of an amount falling within any of the following items of the Table in paragraph 1 of that Schedule—
(i) item 1, 12, 18 or 19, or
(ii) insofar as the tax falls within item 1, item 17, 23 or 24;
(c) interest charged under any provision of this Act (or recoverable as if it were interest so charged); and
(d) interest charged under section 101 of the Finance Act 2009.
An amount by way of penalty ... or interest to which this section applies shall be treated for the purposes of the following provisions as if it were an amount of tax.
Those provisions are—
(a) sections 61, 63 and 65 to 68 of this Act;
(b) section 35(2)(g)(i) of the Crown Proceedings Act 1947 (rules of court: restriction of set-off or counterclaim where proceedings, or set-off or counterclaim, relate to tax) and any rules of court imposing any such restriction;
(c) section 35(2)(b) of that Act as set out in section 50 of that Act (which imposes corresponding restrictions in Scotland).