ATO consultation practices
As some members may be aware, the Commissioner of Taxation made a number of announcements in relation to the ATO’s consultation arrangements at the recent National Tax Liaison Group meeting of 13 June 2013. An overview of the ATO’s revised consultation framework can be accessed.
The Tax Institute is aware of the need for effective consultation in ensuring the best outcome in tax law design, implementation and interpretation.
As both the ATO and many members expend significant resources in consultation, the ATO’s efforts to target those resources to maximise benefit from our mutual investment are welcome.
The Tax Institute’s members have a long history of engaging in consultation to develop and apply tax laws in the national interest. Our consultation efforts have spanned across technical issues, industry focussed issues and ATO systems-related issues.
We are broadly supportive of the objectives of and principles underpinning this proposed framework. Furthermore, we broadly agree that both the ATO and external participants stand to benefit from the potential synergies in a central consultation model or ‘hub’. We also foresee that this model has the potential to increase the effectiveness of consultation and may be better suited to ensuring that the ATO consults on the right issues with the right people at the right time, in comparison to the current consultation model.
However, we are also aware that many of the necessary implementation details are not included in the consultation framework as presented. We are currently working with the ATO to address further development and implementation considerations. These include the best manner in which the professional associations can assist the ATO in the agency’s pursuit of these objectives. We are also discussing the ongoing role that the professional associations can and should play in relation to the hub, as well as some aspects of the hub’s design that would be of benefit to the new consultation framework.
Our internal technical sub-committees are an integral part of The Tax Institute’s policy, advocacy and consultation activities. The ATO changes will not result in immediate changes to our sub committees, but they will play a part in our decisions on the composition, role and function of our sub-committees over the coming months.
As always, I welcome your input in relation to how The Tax Institute can best take member suggestions, concerns and priorities into account and harness the expertise of our members in undertaking our advocacy and consultation activities.
And of course, after the tumultuous political events of this week, Australia has a new Treasurer. The Hon Chris Bowen MP has been appointed to replace Wayne Swan, who resigned his Ministry after the change of Labor leadership.
Chris Bowen brings with him 18 months worth of experience as an Assistant Treasurer, which we hope will stand him in good stead to get on with the job of much needed reforms to our tax system. These include trust tax reforms and clearing the backlog of more than 100 outstanding tax measures that are yet to be legislated.
We look forward to continuing our open and constructive working relationship with the Treasurer’s office.
Robert Jeremenko CTA is Senior Tax Counsel of The Tax Institute.
The Tax Institute is Australia’s leading professional association in tax. Its 13,000 members include tax agents, accountants and lawyers as well as tax practitioners in corporations, government and academia.