Error in taxpayer's document attributable to another person

1A

1

A penalty is payable by a person (T) where—

a

another person (P) gives HMRC a document of a kind listed in the Table in paragraph 1,

b

the document contains a relevant inaccuracy, and

c

the inaccuracy was attributable to T deliberately supplying false information to P (whether directly or indirectly), or to T deliberately withholding information from P, with the intention of the document containing the inaccuracy.

2

A “relevant inaccuracy” is an inaccuracy which amounts to, or leads to—

a

an understatement of a liability to tax,

b

a false or inflated statement of a loss, or

c

a false or inflated claim to repayment of tax.

3

A penalty is payable under this paragraph in respect of an inaccuracy whether or not P is liable to a penalty under paragraph 1 in respect of the same inaccuracy.