Serious misdeclaration penalty – Correction of errors – Whether underdeclaration of liability could correct an overdeclaration in a previous quarter – Whether the expression ‘any period’ could be construed to mean any period other than the period in which the misdeclaration occurred – Finance Act 1985, sec. 14(5A).
The issue was whether the appellant had properly incurred a serious misdeclaration penalty when it underdeclared its liability and in doing so partially corrected a greater over-declaration of liability in a previous quarter.
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