(1) Where an accountable person is in doubt as to the correct application of law to, or the treatment for tax purposes of, any matter to be included in a return or additional return to be delivered by such person under this Act, then that person may deliver the return or additional return to the best of that person's belief but that person shall draw the Commissioners' attention to the matter in question in the return or additional return by specifying the doubt and, if that person does so, that person shall be treated as making a full and true disclosure with regard to that matter.

(2) Subject to subsection (3), where a return or additional return, which includes an expression of doubt as to the correct application of law to, or the treatment for tax purposes of, any matter contained in the return or additional return, is delivered by an accountable person to the Commissioners in accordance with this section, then section 51(2) does not apply to any additional liability arising from a notification to that person by the Commissioners of the correct application of the law to, or the treatment for tax purposes of, the matter contained in the return or additional return the subject of the expression of doubt, on condition that such additional liability is accounted for and remitted to the Commissioners within 30 days of the date on which that notification is issued.