Document ID: chunk:federal_register_of_legislation:C2025C00180:clause:1_1
Version: federal_register_of_legislation:C2025C00180
Segment Type: clause
Provision Reference: sch 1 cl 1
Character Range: 1319065–1320422

1                    having regard to any relevant matters, it is reasonable to conclude that an entity that (alone or with others) entered into or carried out the *scheme, or part of it, did so with the sole or dominant purpose of that entity or another entity getting a *transfer pricing benefit from the scheme  the sum of:
                                                                                                                                                                                                                                                                                                                           (a) 50% of your *scheme shortfall amount, to the extent that it is not attributable as mentioned in paragraph (b); and
                                                                                                                                                                                                                                                                                                                           (b) 25% of your scheme shortfall amount, to the extent (if any) that it is attributable to the entity, or the entity's agent, treating the adjustment provision as applying (including not applying) to a matter (or identical matters) in a particular way that is *reasonably arguable