60-545 Defences to penalty for improper issue of a VAT invoice
A defence to the penalty for the improper issue of a VAT invoice is if the person shows that he has a ‘reasonable excuse’ (VATA 1994, s. 67(8); ¶59-660).
As with other defences to a penalty, an insufficiency of funds is not a reasonable excuse. Similarly, where reliance is placed on any other person to perform any task, neither that reliance nor any dilatoriness or inaccuracy on the part of the person relied on is a reasonable excuse (VATA 1994, s. 71). How these restrictions have been interpreted by the courts is discussed at ¶59-670ff.