A combined discount of 35% for guilty plea and assistance to authorities (including approximately 10% for past and future assistance) was upheld as within the customary range for market manipulation and corporate dishonesty offences. The observations in R v Sukkar that a discount in excess of 40% should very exceptionally be applied absent evidence of disadvantage in custody were confirmed as a general approach, not a rigid cap. Substantial accumulation of sentences for distinct offences arising from the same corporate context does not offend the totality principle where the offences involve separate courses of conduct.
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