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9. After paragraph (15) insert—
“(15A) A person who—
(a)on 31 March 2012 was registered for VAT with an effective date of registration before that date,
(b)was not as at 31 March 2012 required to make a return required by regulation 25 using an electronic return system, and
(c)fails to comply with paragraph (3),
is only liable to a penalty in relation to returns made for prescribed accounting periods which end on or after 31 March 2013.”.
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