106D(1)
A person who is required by a notice under section 8 to make and deliver a return for a year of assessment commits an offence if, at the end of the amendment period—
(a) the return contains an inaccuracy the correction of which would result in an increase in the amount of income tax or capital gains tax (or both) that is chargeable for the year of assessment on or by reference to offshore income, assets or activities, and
(b) the amount of that increase exceeds the threshold amount.
106D(2)
It is a defence for a person accused of an offence under this section to prove that the person took reasonable care to ensure that the return was accurate.
106D(3)
In this section "the amendment period" means the period for amending the return under section 9ZA.