My Lords, this is the first of a series of amendments relating to penalties. Amendment 22 tries to create a defence to a penalty. I say straightaway that I do not have any principled objection to penalties as such, but the amendment tries to make sure that, when a penalty demand is made, if the ratepayer had reasonably relied on published Valuation Office Agency guidance or specific advice given about what was not relevant, that should be a relevant defence.
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