Minor breach principle: penalties must be proportional, require an opportunity to be heard, and can be mitigated by voluntary disclosure.

Penalties must not be imposed for a minor breach-including small-value tax matters or easily rectifiable documentation errors made without fraud or gross negligence-and must be commensurate with the breach's severity. No penalty may be imposed without giving the person an opportunity to be heard. Penalty orders must specify the nature of the breach and the legal basis for the penalty, voluntary pre-discovery disclosure may mitigate penalty, and the section does not apply to penalties expressly fixed as a sum or percentage.

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