1. Where adjustments made to a return filed on time are subject to penalties that do not have the same rate, the penalties are calculated by adding the adjustments to the items declared in descending order of the different rates applicable. The same rule applies where adjustments reduce a deficit or credit and penalties are applied in respect of the year or financial year of allocation.
2. Where adjustments are made to a late return, the increase provided for by Article 1728 applies, excluding the increases provided for by Article 1729, both to the duties resulting from the late return and to the duties resulting from the adjustments made to the return. However, the surcharges provided for in article 1729 replace the surcharge for late filing on the portion of the duties resulting from the adjustments where their rate is higher.