Despite the provisions of any tax Act, the Commissioner must, pursuant to the making of a valid voluntary disclosure by the applicant and the conclusion of the voluntary disclosure agreement under section 7 —
| (a) | not pursue criminal prosecution for any statutory offence under a tax Act or a related common law offence; |
| (b) | grant 100 per cent relief in respect of any penalty and additional tax (excluding a penalty imposed in terms of regulation 5 of the regulations issued under section 75B of the Income Tax Act or in terms of a tax Act for the late submission of a return or for the late payment of tax); and |
| (c) | grant, in respect of a person described in— |
| (ii) | section 3(2), 50 per cent, |
relief in respect of interest otherwise payable, up to the date of assessment described in section 9.
