Avoiding a bum RAP

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Publication date: 01 Feb 05


Taxpayers intending to take a contentious approach to their tax need to ensure at least a 50 per cent chance of success if the matter went to the AAT or Federal Court. Where that taxpayer's interpretation is not based on a 'reasonably arguable position', the taxpayer becomes liable to shortfall penalties.

Author profile:

Prof Robin Woellner CTA
Robin is Pro-Vice-Chancellor of Law, Business and the Creative Arts, at James Cook University. Robin was the Foundation Dean of the College of Law and Business in the University of Western Sydney and was previously the Foundation Dean of the Faculty of Law at the University of Western Sydney, Macarthur. Robin has taught and has carried out significant research on tax administration, and in particular ATO tax audit practice, tax compliance costs, legal professional privilege and related areas. He is the senior author of a leading tax textbook, Australian Tax Law, as well as a number of other books, and has written over 100 articles, notes and reports on taxation, company, commercial and health law.
Current at 01 July 2010
Click here to expand/collapse more articles by Prof Robin H WOELLNER.


This was presented at NSW Annual Intensive Retreat: Managing tax risk for corporate taxpayers.

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Avoiding a bum RAP
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