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Tax dispute lifecycle - PowerPoint PPT Presentation


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Tax dispute lifecycle. ?. Review & Finalisation. Matter. Risk review. ATO audit. Objection. Objection. Litigation. Transaction. Risk profiling Comprehensive Issue specific. Requests for information. Requests for information Informal and / or formal approach

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Tax dispute lifecycle

?

Review & Finalisation

Matter

Risk review

ATO audit

Objection

Objection

Litigation

Transaction

  • Risk profiling
  • Comprehensive
  • Issue specific
  • Requests for information
  • Requests for information
  • Informal and / or formal approach
  • Section 263/264/ 264A notices
  • Initial ATO audit position paper
  • Taxpayer response
  • Independent Review process for certain taxpayers
  • Final ATO audit position paper
  • Assessment / Amended Assessment (primary tax, interest and penalty)
  • Grounds
  • Facts, Evidence and Law
  • Requests for information (if required)
  • Objection Decision
  • Time limits for appeal to Federal Court / AAT
  • Federal Court or AAT

Ongoing engagement between taxpayer / advisor / Counsel and ATO

Debt Collection and Recovery – Agreements with ATO; Freezing Orders

Potential ADR and settlement opportunities