Yeah, this is the confusion - it's difficult to write it out in a way that isn't ambiguous! I think the fact that there are two numbers, the higher of which is the maximum fine, may imply to some people that the lower figure is the minimum - i.e. if 4% of your global turnover is €100m then €20m is the minimum - but of course there in fact isn't a minimum. It might have helped comprehension if there had been an arbitrary minimum figure - say €100 - to anchor the discussions.

The problem with that is that it would introduce a minimum fine, where currently there doesn't need to be a fine at all (if you coöperate).

Ah, I see what you mean now. That's not how I understood it, but some people might.