Using settlements to resolve tax disputes : practical implications

As most taxpayers and their advisers would be aware, tax disputes are an unavoidable aspect of our complex Australian tax system. This has been the case for many years but the manner in which such disputes are resolved has changed markedly and continues to do so. In the 1980s it is fair to say that there was very little prospect of resolving a dispute, prior to a taxpayer referring a disallowed objection to the Administrative Appeals Tri- bunal (AAT) or the Federal Court. Settlement was usually a matter for consideration at the steps of theAAT or the court. Times have changed and the ATO has responded to those changes. Today settlements are one of the dispute resolution strategies used by the ATO.