Paragraph 11 I1I2

For paragraph 23(1) (no liability where there is reasonable excuse for failure) substitute—

“(1)

If P satisfies HMRC or (on appeal) the First-tier Tribunal or Upper Tribunal that there is a reasonable excuse for a failure to make a return—

(a)

liability to a penalty under any paragraph of this Schedule does not arise in relation to that failure, and

(b)

the failure does not count for the purposes of paragraphs 13B(2), 13C, 13G(2) and 13H.”