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(1) A person who fails to maintain proper documents as requiredby a tax law is liable to pay for each month or part of a month duringwhich the failure continues

(a) seventy- five percent of the tax attributable to that periodwhere the failure is deliberate; or

(b) in any other case, the lesser of the amount referred to inparagraph (a) and two hundred and fifty currency points.

(2) The Commissioner-General shall determine tax attributableto a period on a just and reasonable basis including apportioning taxassessed with respect to a larger period or by reference to taxable eventshappening within the period.