The Act Part 8 – Penalties Chapter 3 — Penalties Relating to Inaccuracies Section 191 – Special reduction in penalty under this Chapter
228.This section provides that Revenue Scotland may reduce a penalty (including any interest applied) if it thinks it reasonable to do so because of special circumstances and the penalty is applied under sections 182, 185 and 186. A person’s ability to pay tax or the fact that a potential loss of revenue from one taxpayer is balanced by a potential over-payment of another are not reasons under which the penalty can be reduced.