On 21 February 2007, the ATO issued Practice Statement PS LA 2007/6 entitled "Guidelines for settlement of widely-based tax disputes". The purpose of the Practice Statement is to set out practical guidance for the settlement of widely-based tax disputes including but not limited only to disputes involving taxpayers who have participated in tax planning arrangements (whether subject to the general anti-avoidance provisions or otherwise).
The Practice Statement advises that a Widely-based Settlement Panel has been established to provide advice to decision-makers about offers and proposals to settle widely-based tax disputes involving at least 20 taxpayers.
The Practice Statement must be read in conjunction with the Code of Settlement Practice which provides general guidance about settlement of taxation disputes.
For a copy of PS LA 2007/6, go here