Worldwide Disclosure penalty leaflet FS17 wrong?

Notified HMRC of a disclosure after 30/9/18 conflicting HMRC advice in CC/FS17

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Happy New Year to all AccountingWeb colleagues.

Client has ofshore savings in India.  Left off his SA returns.  After Sept 2018 instructed us to Notify to HMRC under Worldwide Disclosure Facility.  Did so.

I carefully read Leaflet CC/FS17 https://assets.publishing.service.gov.uk/government/uploads/system/uploa...

It says at start "You will be liable to a minimum penalty of 100% of the tax you owe in relation to any offshore issues for the tax years 2015 to 2016 and earlier. This is unless you have fulfilled one of the limited criteria for supplying information after 30 September 2018"

But then it goes on in page 3 to set out penalty rates for inaccurate returns, based on behaviour and the offshore country.  For example "Country in category 2 Unprompted 0% to 45% "

I advised client of expected settlement figures based on this 0-45% range.  Now when I go to complete the online Disclosure it is saying 100% penalty for years to 2015/16.  Rang WDF helpline and they say use 100% and had nothing to say on the inconsistency with their leaflet.

Any thoughts please?

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