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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