25(1)Liability to a penalty under paragraph 22 or 23 does not arise if the person satisfies HMRC or (on an appeal notified to the tribunal) the tribunal that there is a reasonable excuse for the failure.
(2)For the purposes of this paragraph—
(a)an insufficiency of funds is not a reasonable excuse unless attributable to events outside the person’s control,
(b)if the person relies on another person to do anything, that is not a reasonable excuse unless the first person took reasonable care to avoid the failure,
(c)if the person had a reasonable excuse for the failure but the excuse has ceased, the person is to be treated as having continued to have the excuse if the failure is remedied without unreasonable delay after the excuse ceased.