Transcription 18/11/2025, 10:04:57 PM

Notes

**QUESTION TWO: PARTNERSHIPS AND COMPANIES** --- **iii:** • **Statute Bar Exceptions:** The Commissioner may amend an assessment to increase the amount of tax payable after the usual 4-year statutory period in circumstances where: - The return provided by the taxpayer is fraudulent or willfully misleading; or - The taxpayer amounts to Civil Evasion (which includes the omission of income of a particular nature or from a particular source). • **Shortfall Penalty:** Given the circumstances where the taxpayer amounts to Civil Evasion (which attracts a penalty of 150% of the tax in issue), the penalty may be adjusted for the following factors: - Previous good behaviour (50% reduction); - Voluntary disclosure (75% or 40% reduction depending on whether pre- or post-notification of a particular situation); - The culpable behaviour of the taxpayer (25% increase). The discrepancy and the culpable behaviour of the taxpayer, which amounts to Civil Evasion, attract a penalty of 150% of the tax in issue. (✓ one mark each, for a maximum of any two of the above factors) **20 MARKS** **(3 marks)** --- **QUESTION TWO: PARTNERSHIPS AND COMPANIES** **a) Partnerships:** See attached I...