I think that the answer will depend on what the governing modes of failure are:
1) For tension or squash load, the holes will reduce the [As * Fy] capacity but that may not matter if the reduced [As * Fu] capacity is still higher than the unreduced [As * Fy] capacity.
2) For global compression buckling, holes placed away from midspan will likely have no impact at all.
3) For local wall buckling or tension lag, we'd need to know the loads and the layout of the holes & connections.
For many, but not all, possible failure modes, your % reduction is probably a conservative approach when used judiciously.