A combined discount for plea and assistance should not normally exceed 40% unless there is evidence that the offender will serve the sentence in more onerous conditions as a result of giving assistance; the court no longer assumes that an offender who has given assistance will spend any custodial period in more onerous conditions. When sentencing for a common law conspiracy to defraud, the court must have regard to the maximum penalties for all the substantive offences which are the subject of the conspiracy, not just a single statutory offence. The fact that an offender has not previously served a prison sentence is not, by itself, a proper basis for finding special circumstances.
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