Penalties under section 215C: general 215E Reasonable excuse for failure to comply 30 (1) Liability to a penalty under section 215C does not arise if the person satisfies Revenue Scotland or (on appeal) the tribunal that there is a reasonable excuse for the failure to comply. (2) For the purposes of this section— (a) an insufficiency of funds is not a reasonable excuse unless attributable to 35 events outside the person’s control, (b) if the person relies on another person to do anything, that is not a reasonable excuse unless the first person took reasonable care to avoid the failure to comply, and 26...