The Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016

Matters to be disregarded in relation to liability to penalties

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15.—(1) Liability to a penalty under regulation 12, 13 or 14 does not arise if the person otherwise liable to the penalty satisfies Revenue and Customs (or on an appeal notified to the tribunal, the tribunal) that there is a reasonable excuse for the failure or the provision of inaccurate information.

(2) For the purposes of this regulation it is not a reasonable excuse—

(a)that there is an insufficiency of funds to do something; or

(b)that a person relies on another person to do something.

(3) If a person has a reasonable excuse for a failure but the excuse ceases, the person is to be treated as continuing to have the excuse if the failure is remedied without unreasonable delay after the excuse ceases.