Any person who wilfully evades payment of a tax in terms of Article 21 or who secures for himself or another an unlawful tax advantage shall be liable to a fine of up to three times the amount of the tax evaded or of the advantage.
If the offence is committed through negligence, the penalty is a fine of up to the amount of the tax evaded or of the advantage.
If it is not possible to ascertain the precise amount of the tax in figures, it is estimated.
An attempt to secure an unlawful tax advantage for oneself or for another is a criminal offence.
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