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On 20 January 2015, Andrew Mills, ATO Second Commissioner gave an address entitled "It’s time for tax (administration) reform" to the Australasian Tax Teachers’ Association 27th annual conference held at the University of Adelaide, Adelaide, South Australia.

Topics covered in the address include:

  • The need for change
  • Building trust and fostering willing participation
  • Dispute resolution
  • Law design
  • Statutory Remedial Powers
  • Review of public advice and guidance products
  • External Compliance Assurance Process (ECAP) pilot
  • International action

Of law design, Mr Mills said:

"It has often been said that because business is much more complex the law has to be complex. This is a jump in logic, it doesn’t follow, it is a non sequitur. Complex laws add to the complexity of business – businesses have to adapt their transactions to avoid unintended consequences and double taxation. Complex laws tend to create gaps and unintended points of non-taxation. Complex laws have also tended to add to uncertainty rather than reduce it."

However, Mr Mills acknowledged that the ATO only has an "advisory role" in law design:

"The ATO is strengthening its relationships with Treasury at various levels to be more active and supportive in law design and development. However, at the end of the day, the ATO plays an advisory role, and policy matters relating to taxation are the preserve of government."


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