Tax & ATO News Australia
Last Friday, the Federal Court held that services supplied under the uberX service constitute “taxi travel” within the meaning of s 144-5 (1) of the A New Tax System (Goods and Services Tax) Act 1999 (Cth).
To give context to this dispute, following the rise in popularity of the ride sharing platform the Australian Taxation Office (ATO) announced in 2015 that Uber drivers will have to register and pay GST, regardless of turnover. The general rule regarding registration is that an enterprise with a turnover of less than $75,000 is not required to register for GST. An exception to this rule is Section 144-5(1) which requires a person who is carrying on an enterprise of supplying ‘taxi travel’ to be registered for GST regardless of turnover. Section 195-1 of the GST Act goes on to define ‘taxi travel’ as ‘travel that involves transporting passenger, by taxi or limousine, for fares’.
The Australian Taxation Office (ATO) took the position that the Uber platform fell within this exception. However Uber disagreed with this position and sought a declaration from the Federal Court that the services provided by UberX drivers did not constitute taxi travel.
The applicant made submissions on the construction of ‘taxi travel’ claiming:
‘Taxi Travel’ was intended to apply only to the taxi industry as the legislature did not seek to deal with this issue in any other industry.
- The statutory context suggests that the words “taxi” and “limousine” bear a trade or non-legal meaning. Alternatively the ordinary meaning of the words “taxi” and “limousine” was heavily influenced by the underlying regulatory regime.
- The disjunctive “taxi or limousine” in the definition of s195-1 provides that “taxi” and “limousine” have different meanings.
Using the above mentioned arguments on statutory construction, the applicant put forward factual arguments distinguishing Uber from Taxis. The applicant contended that Uber services did not display the essential operational features of a taxi, on the basis that Uber vehicles do not show markings, the access is limited to Uber licensees (App Users), payment systems and calculations differ and Uber drivers are not required to display a fare meter.
The respondent’s made submissions that:
“Taxi travel” is to be construed as a whole and connotes the transport, by a person driving a private vehicle, for a fare irrespective of whether the fare is calculated by reference to a taximeter.
- The services supplied by Uber demonstrate the essential features of transport “by taxi” and “by limousine”.
- The applicant incorrectly relied on the regulatory regimes applying to the taxi industry.
The Commissioner in support of its submission on the construction of ‘taxi travel’ used dictionary definitions to help identify the key features of a ‘taxi’ in ordinary understanding.
Furthermore the Commissioner made submissions that the difference between a limousine and a taxi was that a limousine is not calculated by reference to a taximeter and will need to be pre-booked. Therefore, “limousine” could apply to any hire car.
Justice Griffiths “accepted the Commissioner’s submission that the word “taxi” is a vehicle available for hire by the public and which transports a passenger at his or her direction for the payment of a fare that will often, but not always, be calculated by reference to a taximeter”. In reaching this decision, consideration was placed on principles of statutory interpretation. Further to this the dictionary definitions the Commissioner relied upon provided the court with a supporting context of this interpretation.
However, Griffiths J rejected the Commissioner’s position that limousine was not confined to luxury cars. Instead the ordinary meaning of limousine “was a private luxurious motor vehicle which is made available for public hire and which transports a passenger at his or her direction for the payment of a fare”. Although the present matter involved a Honda Civic which did not meet this definition, Griffiths J recognised this position may be different in cases of other UberX drivers who do use luxury cars.
Ultimately this decision will impose huge compliance burdens on Uber and its drivers. Particularly Uber drivers will now have to register both an Australian Business Number and register for GST, charge an additional 10%, lodge Business Activity Statements and claim Input Tax Credits.
With this being another win for the Commissioner, it can be expected that there will be a crackdown in tax compliance within the ride sharing industry.
Co-authored with Ben Caratti
Posted in: Tax & ATO News Australia at 09 March 17
Consultation paper September 2016: Proposed changes to penalties for small business and individuals.
The ATO has recently released a consultation paper titled ‘Proposed changes to penalties for small business and individuals.’ More information on the proposed changes can be found on the ATO website.
Essentially, under the proposed changes, the ATO will provide ‘one chance’ before applying a penalty in the following circumstances:
- For certain small businesses and individual clients, the ATO will not apply penalties for false or misleading statements for failure to take reasonable care for errors made in income tax returns and activity statements, and
- the ATO will not apply failure to lodge on time penalties for late lodgement of income tax returns and activity statements
The ATO is of the opinion that it is open to the Commissioner to exercise his general powers of administration to give effect to these changes, and therefore a law change is not required.
The following parameters would apply to this proposal:
- The one chance policy would be available to small businesses (with turnovers under $2 million) and individuals, subject to some criteria, with eligible taxpayers being informed at the time that the ‘one chance’ opportunity is provided.
- This policy would not extend to taxpayers who demonstrate reckless or dishonest behaviour, or those who disengage or cease communicating with the ATO during an audit or review
- Those who receive their one chance will be given a clear explanation of their error, and what they need to do to get things right in the future.
- After the one chance has been provided, failure to lodge on time penalties would automatically apply if lodgement was not received by the due date.
The ATO claims that this policy is designed to benefit the taxpayer, as the taxpayer will save time and money by, for example, avoiding the need to research penalty information, lodge objections, and of course, release from the penalties that would otherwise be imposed.
However, those with a more cynical eye, or those who have more experience in dealing with the ATO, will likely have a different idea about the ATO’s motives, as well as the possible effects of the proposed changes.
Firstly, it is possible that these new rules may encourage overzealous auditors to circumvent the one chance policy by pursuing taxpayers for the 50% penalty rate for reckless or dishonest behaviour where they would not have previously.
There are also areas of uncertainty which have not yet been addressed by the ATO. Say, for example, that a taxpayer has not lodged their returns for the 2012, 2013, and 2014 financial years. In light of an audit, would the one chance rule apply to all three years, or just to the first year, with penalties then being automatically assessed for the following years?
The ATO’s intentions surrounding future penalties after one chance has been given are also cause for concern, particularly in light of the ATO’s statement that,
‘After the one chance opportunity has been provided, failure to lodge on time would automatically apply if lodgement was not received by the due date.’
Whilst according to the legislation penalties do indeed automatically apply, the current opportunity to contact the ATO to explain the reasons for delay seeking an exercise of the Commissioner’s discretion to remit the penalty seems to be closed to a taxpayer who has been given ‘one chance’.
A taxpayer with good grounds to be treated leniently would have to pursue more formal legal avenues, which would likely mean greater costs and more time, a result that is antithetical to the ATO’s supposed intentions.
While these proposed changes may appear good natured and well-intentioned at first glance, it remains to be seen whether the likely results of the changes will result in a net positive for the taxpayers of Australia.
Posted in: Tax & ATO News Australia at 10 October 16
I have blogged before about the change in the ATOs audit and dispute resolution approaches.
While some of this is great (for example, the ATO’s desire to resolve more disputes without going to court), one area that is increasingly concerning me is how the ATO uses Taxpayer Alerts in the audit process.
The ATO says that ..
We issue taxpayer alerts to warn you of our concerns about new or emerging higher risk tax or superannuation arrangements or issues that we have under risk assessment. Our aim is to share our concerns early to help you make informed decisions about your tax affairs.
This is a great concept: getting ahead of the curve and preventing a taxpayer from diving into an aggressive tax avoidance scheme is precisely the sort of pro-active and effective use of scarce resources that taxpayers want to see.
But the reality is that the ATO increasingly is using Taxpayer Alerts as an aggressive audit tool, rather than pro-active engagement.
I have seen a number of recent cases where the ATO has changed its position from established tax rulings and departed from established court judgments and created a new high water mark in a Taxpayer Alert. The ATO then uses this new high water mark as the benchmark to determine whether the taxpayer should be audited, and if so, if an assessment should issue.
This is particularly of a concern where the Taxpayer Alert identifies something that was done years in the past.
I support the use of Taxpayer Alerts when looking at amnesties for those people who may have already engaged in aggressive tax avoidance.
It bothers me greatly when auditors point to a taxpayer alert (particularly one that stretches the application of tax law beyond what is the ATO’s existing position) as justification for commencing an aggressive audit against a taxpayer. When that happens the taxpayer is bewildered, feels victimised and cannot understand why their accountant said that the arrangement was legitimate.
If you have received an audit or notification with reference to a taxpayer alert, please contact me. I am keen to pursue this issue further so that the use of taxpayer alerts is confined to worthwhile, proactive tax administration, not aggressive and ultimately pointless audits.
Posted in: Tax & ATO News Australia at 26 July 16
Tax is a notoriously perplexing area of law.
However, few things are more perplexing than the inconsistent administration of the ATO’s disputed debt recovery policies.
Strictly speaking, the Commissioner is free to take whatever steps whenever he pleases, regardless of the existence of a dispute – in fact, sections 14ZZM and 14ZZR of the Taxation Administration Act 1953 are explicit that liability to pay assessed tax is not suspended because of pending reviews or appeals. This means, once assessments are issued, the Commissioner is entitled to do what is necessary to recover. This is what makes PS LA 2011/4 so important – taxpayers need certainty on what they can expect when an assessment is issued and have a genuine dispute, because the ATO does get it wrong, often with disastrous results.
The ATO’s practice statement PS LA 2011/4 attempts, with very limited success, to define and clarify the circumstances in which the ATO will seek to collect and recover disputed debts. Relevantly, paragraph 43 of PS LA 2011/4 provides the Commissioner of Taxation will agree to deferral of recovery action where the Commissioner considers that a genuine dispute exists in regard to the assessability of an amount, but it is unclear on what terms the Commissioner will agree to do so. The practice statement talks variously about 50/50 arrangements (payments of 50% of the underlying debt) and security, but does not make clear the circumstances in which these will be considered.
Regrettably, I have been involved in many cases where a taxpayer has a genuine dispute, and is later exonerated at the conclusion of legal proceedings, but the Commissioner nevertheless proceeds with one of the many debt recovery options available to him in the interim. These include, for example:
- Bankruptcy. This ultimately achieves little in the way of recovering revenue, and can be fatal to a taxpayer’s legal challenge to the assessments the Commissioner relies upon to bankrupt the taxpayer, as the taxpayer’s rights to seek review typically vest with the trustee, or liquidator or administrator of a corporate taxpayer.
- Garnishee notices. These are issued by the Commissioner to third party debtors of the taxpayer, which require the debtors to make payments directly to the Commissioner in lieu of the taxpayer to discharge the taxpayer’s debt. Notices can be issued to a myriad of third parties, including banks and companies. This can severely impact the taxpayer by diverting business profits, proceeds from the sale of real estate, and any number of other debts a taxpayer may rely on for their business and personal use.
- Departure Prohibition Orders (or DPOs), which prohibit a tax debtor from leaving Australia, regardless of whether or not they intend to return, and can be issued where the Commissioner holds a belief on reasonable grounds that it is desirable to do so.
Of course, all are inevitably hotly contested by the taxpayers involved. This simply creates ancillary and costly legal proceedings that can cripple a taxpayer without contributing to the resolution of the underlying dispute. Wasting scarce resources on contested debt recovery proceedings is not in the interest of the Commonwealth or taxpayers.
If the ATO’s true concern is that the debt may not be recovered at all, and that objection proceedings are just delaying the inevitable, then surely the ATO must accept that something that preserves the status quo addresses all of their concerns. Freezing orders are a way of achieving this.
In my view, rather than bankruptcy, garnishee notices, DPOs, or other such irreversible actions, freezing orders are a far better way of addressing the ATO’s concerns that assets may be dissipated, while still allowing the taxpayer to prosecute their case. Instead of depleting the taxpayer’s assets and depriving them of their means to contest their tax liabilities, freezing orders simply preserve the status quo for a period defined by the court to mitigate the dissipation of assets pending a final determination and judgment. Such orders were employed in the recent case of Deputy Commissioner of Taxation v Greenfield Electrical Services Pty Ltd  FCA 653, as well as a sequence of related proceedings in Deputy Commissioner of Taxation v Chemical Trustee Limited (No 4)  FCA 1064 and Deputy Commissioner of Taxation v Hua Wang Bank Berhad  FCA 1014.
Ultimately though, within the current scheme of the tax law, we rely on the good graces of the Commissioner in such matters, and much of the way a matter progresses through review and court processes depends on the attitude of the Commissioner of the day.
My view is that PS LA 2011/4 would benefit enormously from a safe harbour approach, and in my respectful suggestion, the taxpayer should always be within that safe harbour wherever there was a genuine dispute. Such an approach would reflect the ATO’s reinvention, as perhaps would an overarching statement that the purpose of debt recovery is to collect the correct amount of revenue - and, more often than not, reasonable minds will differ as to what that correct amount is.
Written in collaboration with Nicholas Dodds.
Posted in: Tax & ATO News Australia at 08 June 16
Super contributions from a small business standpoint.
Scott Morrison’s budget has been received with mixed reactions, but what effect does it have on small business and super?
The small business capital gains concessions in Division 152 of the Income Tax Assessment Act 1997 can be a fruitful tool for those involved in small business that are looking to add a little spice to their super. Whilst these concessions can be a real boon when properly utilized, there is no comment so far on whether their effectiveness will be impeached by Morrison’s new, slightly stingier, super rules.
A key aspect of the budget was the introduction of a lifetime non-concessional contributions cap of $500,000. The lifetime cap takes into account all non-concessional contributions made on or after 1 July 2007, and will commence at 7:30pm on 3 May 2016. The purpose of this cap, according to the ‘Tax and Super’ Budget overview is to:
“Limit the extent to which the superannuation system can be used for tax minimisation and estate planning. Less than 1% of superannuation fund members have made contributions above this cap since 2007.”
It is important to note that contributions made before commencement cannot result in an excess. However, excess contributions made after commencement will need to be removed or be subject to penalty tax. The cap will be indexed to average weekly ordinary time earnings and is estimated to have a gain to revenue or $550 million over the forward estimates period.
Other relevant Budgetary Measures:
- From 1 July 2017 a $1.6 million superannuation transfer balance cap on the total amount of superannuation that an individual can transfer into retirement phase accounts will be introduced.
- Will require those with combines incomes and superannuation contributions greater than $250,000 to pay 30% tax on their concessional contributions, up from 15%.
- From 1 July 2017, the superannuation concessional contributions cap will be lowered to $25,000 per annum.
- The government will also introduce catch-up concessional superannuation spending by allowing unused concessional caps to be carried forward on a rolling basis for up to 5 years for those account balances of $500,000 or less. This will allow those with lower contributions, interrupted work patterns or irregular paying capacity to make ‘catch-up’ payments to boost their superannuation savings.
- From 2016-17, the unincorporated small business tax discount will be available to businesses with an annual turnover of less than $5 million, up from the current threshold of $2 million, and will be increased to 8%.
Do the new budgetary measures alter the effectiveness of div 152 and small business CGT concessions?
S 292.90 (1) ITAA 1997 states that your non-concessional contributions for a financial year are the sum of:
(a) each contribution under subsection (2)
Subsection (2): a contribution is covered under this subsection if:
(c) it is not any of the following:
(iii) a contribution covered under s 292-100 (certain CGT payments), to the extent that it does not exceed your CGT cap amount when it is made.
Therefore, if the small business CGT concessions are included in section 292.100, they are not covered as a non-concessional contribution, as per the rules of 292.90.
S 292.100 (1) states that a contribution is covered under this subsection if:
(b) the requirement under subsection (2) is met
Subsection (2)(a) the requirement of this subsection is met if the contribution is equal to all or part of the *capital proceeds from a * CGT event for which you can disregard and * capital gain under s152 (or would be able to do so, assuming that a capital gain arose from the event.)
As such it is clear that div 152 small business CGT concessions are not included in the definition of a non concessional contribution, and as such it seems unlikely that they will be included in the $500,000 cap.
There is nothing to suggest that the definition for non concessional contributions will be changed to include div 152 small business capital gain exceptions. We think that these SBC continue to present themselves as a valuable method for those hoping to continue to invest in their super.
Posted in: Tax & ATO News Australia at 18 May 16
The house of representatives committee on taxation is currently accepting submissions into the external scrutiny of the ATO. This is after recent comments from the Commissioner of Taxation, Chis Jordan that there is too much scrutiny of the ATO.
Encouragingly, Liberal Senator, Bronwyn Bishop, has resisted this call, saying that given the ATO’s role is to collect money and this has the potential to effect peoples’ lives, parliamentary scrutiny should remain.
More critically, the power that the ATO has to collect money is virtually unlimited, as I have written about before. This power, coupled with a culture that oscillates between rabidly aggressive (at worst) to uncompromising (at best), means that there is always a real risk that an individual ATO officer will go too far and destroy someone’s life in the meantime. This has happened, and I have personally been involved in many such cases, including cases that are deserving of compensation, so badly has the ATO behaved.
The Inspector General of Taxation, Mr Ali Naroozi, does an excellent job of scrutinizing the ATO, with limited resources. Mr Naroozi is a sensible and appropriately skeptical watchdog and needs more scope to review what the ATO does, not less. It would be an absolute disaster if the parliament was convinced that the ATO should be unsupervised.
If parliament agreed with the Commissioner of Taxation in this regard, the result will only be worse for taxpayers, including in particular those many taxpayers who are ultimately showed to have done nothing wrong. There must be consequences if the Commissioner’s actions cause an individual who has not avoided tax at all to lose their business, their house or worse. This has happened, and must not happen again.
Posted in: Tax & ATO News Australia at 22 March 16
I have written previously on the highly-publicised culture change and reinvention of the ATO, and the steps being taken by Commissioner of Taxation Chris Jordan to modernise the ATO’s approach to review and dispute resolution. However, this has been against the backdrop of the immense debt collection and recovery powers wielded by ATO officers, documented abuses of these powers costing taxpayers their homes and businesses, and recommendations by the Inspector General of Taxation and parliamentary committees to rein in these powers and the potential for their misuse.
In March 2015, the House of Representatives Standing Committee on Tax and Revenue issued a report into tax disputes. After hearing stories from taxpayers and tax professionals who have witnessed ATO maladministration and its consequences firsthand, the Committee made a number of recommendations to curb the ATO’s powers.
The biggest and most significant recommendation of all is that the ATO should bear the legal burden of proving an allegation of fraud and evasion on the part of a taxpayer. Where the ATO makes a finding of fraud or evasion, it enables the ATO to go back indefinitely to raise assessments for years long past. This puts the taxpayer on the back foot from the outset by requiring them to disprove whatever nefarious scheme or mischief the ATO can concoct in its imagination, and forces the taxpayer to rely on aged records that may no longer exist in the task.
This is inconsistent with the operation of all other areas of our law, where the party making the allegation is required to prove that allegation – and you are innocent until proven guilty. But not in tax matters.
Surely then, even the ATO can agree that it is at least fair in some circumstances to shift the burden from the taxpayer to the all-knowing, all-seeing taxman, right?
Wrong. In December 2015, the government rejected the Committee’s recommendation out of hand, suggesting that:
“A shift in the burden of proof to the ATO after a certain period has elapsed would be counter-productive and encourage sham behavior by taxpayers associated with fraud and evasion.”
It also suggested that the fact that the Administrative Appeals Tribunal and the Federal Court consider whether the ATO position on this question is sustainable on the evidence before them in litigation deals adequately with the existence of fraud or evasion.
This is not an explanation that justifies why taxpayers should be unfairly prejudiced. A sham is where someone does something that appears to be one thing, but is actually hiding something else.
The real sham happens when the ATO manufactures a finding of fraud or evasion, without proper evidence, to allow them to tax to someone they do not have the power to assess.
The only real risk is that faced by the ATO: that the ATO would have to do its job better and be accountable to the taxpayer for its actions and decisions, supporting them with proper reasons and proper evidence. Evidently, this is something the government and the ATO are not prepared to do in a meaningful way here.
It seems to me that until the ATO is willing to come to the table and acknowledge the evidence and advice about the misuse of its powers, all the talk of a reinvention and a new way of doing business is exactly that – just talk.
Posted in: Tax & ATO News Australia at 20 January 16
On 1 December 2015, the ATO released its annual report for 2014-15. The report provides statistics, details and commentary on the ATO’s performance across a number of key areas. It also showcases the ATO’s reinvention and recent switch to a more commercial approach to interaction with taxpayers, with a view to achieving better and more sensible outcomes. At the outset of the report, Commissioner Chris Jordan summarises this new way of thinking in his personal review:
“With the intent of building community trust and confidence, we shifted the way we interact with clients and stakeholders to be more collaborative, more relationship-oriented, more outcome and future-focused.”
The report goes on to list significant achievements of the past year, including improvements to the ATO’s dispute resolution process with early engagement, use of independent facilitators, increased alternative dispute resolution, and new settlement guidelines. Continuing to improve results in prevention and early resolution of disputes is also listed as an ATO goal looking ahead. Indeed, this is reflected in a number of statistics made available in the report:
- The ATO settled over 1,000 cases in the 2014-15 year, compared to around 390 the year before. 84% of these were settled prior to litigation, compared to 77% in the 2013-14 year.
- Then, in litigious cases, the ATO also settled 80% of all court cases prior to any hearing.
This not only reflects the ATO’s new commercial approach to dispute resolution, but also a more measured approach to litigation, and the cases the ATO is prepared to contest. Critically, this saves time and money for all parties, where previously a dispute may have spiralled out of control until a Tribunal or Court decision.
We are involved in many negotiated disputes and applaud the ATO’s reinvention in this respect. However, while the ATO grapples with this transition, remnants of the old ATO mindset remain. This is particularly evident in the continuing aggressive and inappropriate use of wide debt recovery powers, and gung-ho auditors looking to make a good impression.
Ultimately, the 2014-15 annual report shows the ATO is taking steps in the right direction at the executive level, but on the front lines, there is still plenty of work to be done.
Posted in: Tax & ATO News Australia at 03 December 15
The Federal Government is seriously considering giving the ATO wiretap powers, or more accurately, powers to access metadata, including stored phone calls, emails and SMSs.
A Government committee has argued that these powers are necessary to protect against serious crime, such as tax fraud, and noted that “Al Capone was caught through the tax system.” I kid you not.
I will leave the critique of an argument that leads from the premise of Al Capone to the conclusion of ATO needing more power to the logicians. My primary concern is that it is absolutely crazy to give the ATO more power when the Inspector General of Taxation and other Federal Government committees have already concluded that the ATO is abusing its current powers.
I have described them as monkeys with machine guns. This will potentially give the monkeys a surface to air missile.
It may surprise people that the ATO does not currently have the power to intercept telecommunications. There is a very good reason for this – the ATO currently must pass on the role of criminal investigation and prosecution to the crime authorities, specifically the Australian Crime Commission and the Australian Federal Police. Those authorities of course have the power to investigate all Federal crimes (including tax fraud), and can access telecommunication to do so.
However, there is a critical oversight role in that any warrant must be approved by a Federal Court judge. While this is quite easy to do in practice, it forces the bodies involved to turn their attention to the existence and seriousness of potential crime.
It is well established that the ATO can use its own significant investigative powers for the purposes of auditing and amending assessments. These powers can be (and are) used without any suspicion of wrongdoing – simply as a fishing expedition. The logic is that this is acceptable as far as it goes, because the ATO is simply raising assessments (although I have huge problems with this power being abused as well).
What happens when the ATO’s wide reaching powers are merged with the kind of powers usually reserved for criminal investigation and then only with the oversight of the courts? The power will be enormous, and the potential for abuse of that power will be correspondingly frightening.
I am genuinely concerned about the impact of these proposed changes on the rights of small businesses and individuals. As always with such measures, it is not the criminals who will be affected – there are already significant powers that can be used appropriately to catch the crooks. The people who will be affected are the kind of people I act for: people who do nothing wrong and are targeted by the ATO because of a data matching computer’s algorithm which no-one truly understands.
This is scary stuff.
Posted in: Tax & ATO News Australia at 28 September 15
Anyone who has received an email from the ATO recently will see that their new email sign offs proudly state “We’re Reinventing”. At least sometimes they do - I suspect some ATO officers remove this logo in some correspondence.
And therein lies the problem with cultural change in an organization as large and entrenched as the Australian Taxation Office. I think the Commissioner, Mr Chris Jordan, is brave and visionary in trying to reinvent the ATO into an organization that is more approachable and responsive to taxpayers. A significant number of ATO officers, particularly in the Review and Dispute Resolution (‘RDR’) section of the ATO are on board with this new approach.
I shared a panel with two Assistant Commissioners on Friday 28th August 2015 in Brisbane to discuss RDR’s approach to mediation and their own project, in-house facilitation.
In-house facilitation is a form of mediation run by ATO officers who truly do act independently. I think this is a brilliant innovation and at its best, works very well. I have been involved in several facilitations, all with great success.
I am greatly concerned, however, that the good intentions of the Commissioner and those in RDR and the goodwill being developed by this approach is being eroded by some people within the ATO who do not believe in it. One matter in particular suggests to me that some within the ATO are prepared to walk away from a concluded deal from a mediation.
Hopefully these issues can be resolved and I look forward to hearing from the RDR Assistant Commissioners as to how they hope to address this problem in the future.
Posted in: Tax & ATO News Australia at 17 September 15
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