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...

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...