Document ID: chunk:federal_register_of_legislation:C2013A00101:clause:2_2
Version: federal_register_of_legislation:C2013A00101
Segment Type: clause
Provision Reference: sch 2 cl 2
Character Range: 38454–39926

2                    item 1 does not apply                                                                                                                                                                                                                                                                                 the sum of:
                                                                                                                                                                                                                                                                                                                           (a) 25% of your *scheme shortfall amount, to the extent that it is not attributable as mentioned in paragraph (b); and
                                                                                                                                                                                                                                                                                                                           (b) 10% 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

Note: For special rules about when transfer pricing treatment is not reasonably arguable, see Subdivision 284‑E.