The approach to administration of the Australian tax system has, over time, fluctuated between an adversarial and a co-operative approach. Currently, consistent with a move to a responsive regulatory strategy, the Australian Tax Office (“ATO”) has expressed its desire for a co-operative...

The rule of law imperative, so often espoused by industrialised nations, is under siege as tax systems attempt to interface with an ever increasingly complex and globally focused business environment. Compliance by taxpayers and enforcement by the tax administrator has become progressively...

In considering how tax administrators should relate to tax intermediaries, one approach has been to move tax administrators from a command and control posture to a more sophisticated form of regulation, as recently endorsed by the OECD's "enhanced relationship" model. For the last decade,...