Losses brought about carelessly or deliberatelyU.K.
26(1)This paragraph applies for the purposes of paragraphs 24 and 25.U.K.
(2)A loss of tax is brought about carelessly by a person if the person fails to take reasonable care to avoid bringing about that loss.
(3)Sub-paragraph (4) applies where—
(a)information is provided to HMRC,
(b)the person who provided the information, or the person on whose behalf the information was provided, discovers some time later that the information was inaccurate, and
(c)that person fails to take reasonable steps to inform HMRC.
(4)Any loss of tax brought about by the inaccuracy is to be treated as having been brought about carelessly by that person.
(5)References to a loss of tax brought about deliberately by a person include a loss of tax brought about as a result of a deliberate inaccuracy in a document given to HMRC by or on behalf of that person.