94BCBAssessment of penalty for failing to register or provide information for purposes of applied global anti-base erosion rules

1. The Commissioner may make an assessment for a taxpayer of the amount of a penalty under section 139ABB that, in the Commissioner’s opinion, ought to be imposed, and the taxpayer is liable to pay the penalty assessed.

2. Despite subsection (1), this section does not apply in so far as the taxpayer establishes in proceedings challenging the assessment that the assessment is excessive or that the taxpayer is not chargeable with the penalty.