Early Engagement Strategies with the ATO



In recent times, we have seen the ATO take steps towards building more open and transparent working relationships with taxpayers. These steps are being taken in the context of the ATO moving away from a traditional enforcement based focus, towards a service based focus.

As part of this exercise, the ATO have introduced some early engagement strategies which are intended to help taxpayers achieve greater degrees of certainty in managing their tax affairs.
These early engagement strategies include:

  • 24-hour call back request;
  • Early engagement advice request; and
  • Complex issue resolution request.

We note the Commissioner is not bound by his opinions provided under these early engagement strategies.  However in using such strategies taxpayers can generally expect to be protected from penalties in the event the Commissioner later rules against them.  Moreover it may be possible to preserve anonymity when using these strategies to seek the Commissioner’s opinion.

This is a very welcome and positive step taken by the Commissioner in working towards a greater degree of collaboration with taxpayers. In addition, we appreciate the Commissioner’s efforts in helping taxpayers manage their tax affairs with greater degrees of certainty.

For instance, we expect that taxpayers will have better and quicker access to anonymously obtaining a preliminary, high-level “yes” or “no” answer to a question on expected tax outcomes, which can often influence whether or not to proceed with a particular transaction.

If you are considering a proposed transaction, or would like to know what may be the Commissioner’s opinion on the tax implications of a prior transaction, please call your Chapman Eastway advisor on (02) 9262 4933.  We would be very happy to explore how we may be able to help you utilise the ATO’s various early engagement strategies.

Disclaimer – This is not considered to be advice.  To the extent permitted by law, this should be considered general information only and no action should be taken based on the above.  Should you require specific advice to rely upon, please contact a Principal at Chapman Eastway.


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