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(1)(a) A person who does not comply with section 64(10)(c)(i), 64(12), 65(3), 86(1), 91C(3) or (4), 91E(3) or (4), 95(9)(a) or 124(7)(a) or Chapter 2, 3, 6 or 7 of Part 9 or any provision of regulations in regard to any matter to which those sections or Chapters relate shall be liable to a penalty of €4,000.

(8) A person who fails to comply with a notice issued under section 124(7)(b) shall be liable to a penalty of €4,000.

(b) Nothing in this subsection shall affect the operation of section 124(3) and (4).

“accountable person” includes a person who is not a registered person and is in doubt as to whether he or she is an accountable person in respect of a transaction and, in that case, references to a return and records are to be construed as referring to a return that would be due under Chapter 3 and records that would be kept for the purposes of Chapter 7 or section 124(7), if that person were in fact an accountable person;

then the accountable person may, at the same time as the accountable person furnishes to the Collector-General the return due in accordance with Chapter 3 for the period in which the transaction occurred, lodge a letter of expression of doubt with the Revenue Commissioners at the office of the Commissioners which would normally deal with the examination of the records kept by that person in accordance with Chapter 7 or section 124(7).

(8) A letter of expression of doubt shall be deemed not to have been made unless its receipt is acknowledged by the Revenue Commissioners and that acknowledgement forms part of the records kept by the accountable person for the purposes of Chapter 7 or section 124(7).

(a) records kept by a person pursuant to this Chapter or section 124(7) and that are in the power, possession or procurement of the person;