Paragraph 10 I1I2

For paragraph 16(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 payment—

(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 as a default for the purposes of paragraphs 6, 8B, 8C, 8G and 8H.”