The Commissioner may remit all or part of an amount of penalty tax payable by a person if the Commissioner is satisfied that—
(a) either—
(i) the person has taken reasonable steps to mitigate, or to mitigate the effects of, the circumstances that resulted in the liability for penalty tax; or
(ii) the circumstances that resulted in the liability for penalty tax were exceptional; and
(b) it would be fair and reasonable to remit all or part of the penalty tax.