Managers of entities

—(1) If an entity fails to pay tax on time, every person who is or has been a manager of the entity, at any time since the relevant time, is jointly and severally liable with the entity and every other such person for payment of the tax. (2) Sub-section (1) applies irrespective of whether the entity ceases to exist. (3) Sub-section (1) does not apply to a manager who has exercised the degree of care, diligence, and skill that a reasonably prudent person in the position of the manager would have exercised in preventing the initial and continuing failure to pay tax. (4) Amounts payable to the Director General by a manager under this section are a personal tax liability of the manager. (5) If a manager pays tax by reason of a liability under sub- section (1), the manager may recover the payment from the entity as a debt due. 54 CAP. 51 Tax Administration and Procedure (6) A manager of an entity may not be assessed for an amount under this section after the period of limitations for collecting the relevant tax from the entity has expired. (7) For the purposes of this section“entity” means any taxpayer other than a partnership, unincorporated body, or an individual; “manager of an entity” includes a person purporting to act as a manager of the entity and, in the case of a company, includes a director, the chief executive officer, and the chief financial officer of the company; and “relevant time” means six months before the events that gave rise to the entity’s tax liability.