(1) In this section, "the specified difference", in relation to a person, means the difference between -

(a) the amount of income tax or, as the case may be, corporation tax payable in relation to the person's or, as may be appropriate, another person's liability to income tax for a year of assessment or to corporation tax for an accounting period, as the case may be, and

(b) the amount which would have been the amount so payable if -

(i) any statement or representation referred to in subsection (2)(a) had not been false,

(ii) any account, return, list, declaration or statement referred to in subsection (2)(b)(i) had not been false or fraudulent, or

(iii) the full amount of income referred to in subsection (2)(b)(ii) had been disclosed.

(2) A person shall, without prejudice to any other penalty to which the person may be liable, be guilty of an offence under this section if -

(a) in relation to the person's liability to income tax for a year of assessment or to corporation tax for an accounting period, as the case may be, the person knowingly makes any false statement or false representation -

(i) in any return, statement or declaration made with reference to tax, or