Taxpayers’ acts in breach of duty under tax law are not punishable unless committed intentionally or negligently.
No taxpayer may be excused from responsibility for administrative penalty by reason of his ignorance of the law, but the penalty may be reduced or exempted as the situation may justify.
In the case of tax collection authorities’ imposition of a fine, consideration shall be given to such factors as the culpability of the taxpayer’s act in breach of duty under tax law, the impact resulted therefrom, and the benefits gained from such an act. Additionally, the financial ability of the taxpayer penalized may also be taken into account.