(1) The amount of penalty payable for a tax default is, subject to this
Division--
(a) 25% of the amount of tax unpaid, or
(b) if the taxpayer is a
significant global entity within the meaning of the Income Tax Assessment Act
1997 of the Commonwealth--50% of the amount of tax unpaid.
(a) the taxpayer (or a person acting on behalf of the
taxpayer) took reasonable care to comply with the taxation law, or
(b) the
tax default occurred solely because of circumstances beyond the taxpayer's
control (or if a person acted on behalf of the taxpayer, because of
circumstances beyond either the person's or the taxpayer's control) but not
amounting to financial incapacity.