(1)  If a tax default occurs, the taxpayer is liable to pay interest on the amount of tax unpaid calculated on a daily basis from the end of the last day for payment until the day it is paid at the interest rate.

(2)  Interest is payable in respect of a tax default that consists of a failure to pay penalty tax.

(3)  Interest is not payable in respect of a tax default that consists of a failure to pay interest.