Minor breach threshold avoids penalty for trivial tax documentation errors, subject to hearing and mitigating disclosure. Officers must not impose penalties for trivial breaches and easily rectifiable documentation errors made without fraud; penalties must be proportionate to ... Summary
Minor breach threshold avoids penalty for trivial tax documentation errors, subject to hearing and mitigating disclosure.
Officers must not impose penalties for trivial breaches and easily rectifiable documentation errors made without fraud; penalties must be proportionate to the breach, follow an opportunity to be heard, specify the breach and applicable provision, and may be mitigated by voluntary pre-discovery disclosure, but these disciplines do not apply where the Act prescribes a fixed sum or fixed-percentage penalty.
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