Sarah Blakelock and Suzie Emery outline the ATO's early engagement process and how KPMG's Tax Dispute Resolution & Controversy can assist.
The Australian Taxation Office (ATO) has announced an early engagement service for practitioners with small to medium enterprise (SME) clients.
The new service will mirror the existing arrangement for large business practitioners and is a positive step for SME taxpayers seeking to obtain some certainty around potential tax liabilities of a transaction at an early stage in the process.
Practitioners will be able to request an early engagement discussion seeking advice on complex transactions. The service is designed to assist in resolving technical tax queries which cannot be resolved through standard channels. It is anticipated that early engagement will assist with provision of advice about new legislation, clarifying the ATO’s position on complex tax law issues and help with legal interpretation.
Once an early engagement request is lodged, the ATO consults with the taxpayer and their advisors to explore the tax technical and factual issues, understand critical dates and timeframes and to discuss the material to be provided in support of the request.
Early engagement with the ATO can save significant time and costs in dealing with tax implications of complex or controversial transactions, particularly where there have been changes to the tax laws. Further details on how to make an early request for assistance can be found on the ATO website.
Our Tax Dispute Resolution & Controversy practice has significant experience in working with tax and business advisors and taxpayers in steering taxpayers successfully through the early engagement process and can assist you as required.