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(1) A person who knowingly or without reasonable excuse aids, abets, counsels or induces another person to commit an offence under section 78 to 84 is liable to pay a penalty of one hundred percent of the tax shortfall.

(2) In this section, “tax shortfall” means the underpayment of tax that, in the opinion of the Commissioner-General, may have resulted if the offence had been committed and had gone undetected.