Tax Administration



More than five years have passed since the implementation of the Base Erosion and Profit Shifting (BEPS) package through the Inclusive Framework. Tax certainty remains… Read More ›

Does the OECD’s Peer Review Process Ensure Certainty for Tax Treaty Dispute Resolution Mechanisms?

Over the last two decades, tax authorities around the world have introduced cooperative compliance approaches to increase corporate tax compliance. These approaches open the possibility… Read More ›

The Cooperative Approach to Corporate Tax Compliance

Trust property which persons effectively control may be forfeited to the Commonwealth as ‘unexplained wealth’ unless a court is satisfied that the property was not… Read More ›

Trusts, Tax and Criminal Law

From time to time, there have been various reviews into whether taxable income should be aligned with accounting income in order to reduce some of… Read More ›

How to Build a Transformational Tax System for Small Businesses Using Technology as a Pathway to Reform

We stand on the cusp of an artificially intelligent tax administration world. The transformation of tax authorities to this near-future state appears inevitable and unstoppable.… Read More ›

Remapping the Frontier of Tax Authority Immunity from Taxpayer Suit in a Digital Tax Administration World

Every person must, if required by the Commissioner of Taxation, lodge an annual return for income tax purposes. Once lodged, the Commissioner must make an… Read More ›

Overturning an Assessment Where the ATO Merely Suspects Fraud or Evasion

The Commissioner of Taxation’s power to issue notices under section 260-5 of Schedule 1 to the Taxation Administration Act 1953 (otherwise known as garnishee notices)… Read More ›

ATO Garnishee Notices: Frustrating Corporate Rescue Policy

My paper recently published in the Australian Tax Forum, centres on the implications of Farah Custodians Pty Limited v Commissioner of Taxation (No 2), an… Read More ›

Suing Negligent Australian Tax Officials – Recent Judicial Developments & Possible Future Directions

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