654. Penalties for errors.

A penalty is payable by a person ('P') where P gives HM Revenue and Customs a return1 which:

  1.  

    (1)     contains an inaccuracy which amounts to or leads to: (a) an understatement of a liability to tax2; (b) a false or inflated statement of a loss3; or (c) a false or inflated claim to a repayment4 of tax; and

  2.  

    (2)     the inaccuracy was careless5 or deliberate on P's part6.

A penalty is payable by a person ('T') where another person ('P') gives HM Revenue and Customs a document7 which contains a relevant inaccuracy which is attributable to T deliberately supplying false