Penalty for unpaid tax

13.  The circumstances prescribed for the purposes of section 59E(4) of the Management Act (penalty not exceeding twice the amount of interest charged by virtue of regulation 7 on any unpaid amount in respect of the total liability of a company for an accounting period) are where—

(a)the company, or a person acting on its behalf, deliberately or recklessly fails to pay the amount in question in accordance with regulation 5;

(b)the company, or a person acting on its behalf, fraudulently or negligently makes a claim for repayment of an amount under regulation 6(2).