27 Exceptions from section 26

27  Exceptions from section 26

(1)     A person is not liable to a penalty under section 26 if he satisfies—

(a)     the Commissioners, or

(b)     on appeal, an appeal tribunal,

that there is a reasonable excuse for his conduct.

(2)     For the purposes of subsection (1) none of the following is a reasonable excuse—

(a)     an insufficiency of funds available to any person for paying any relevant tax or duty

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