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Feature: Challenging assessments – a taxpayer’s review and appeal rights


A taxpayer’s ability to challenge an assessment is significantly curtailed by the operation of the conclusive evidence provisions together with s 175A of the Income Tax Assessment Act 1936 (ITAA36) which confines a taxpayer to the objection, review and appeal provisions set out in Part IVC of the Taxation Administration Act 1953 (Cth) (TAA53).

Author profiles

Sarah Blakelock
Photo of author, Sarah Blakelock Sarah is a Partner in KPMG Law’s Tax Dispute and Controversy practice. Sarah has more than 17 years’ experience focusing on the prevention, management and resolution of tax disputes. She specializes in risk reviews and audit management, evidence gathering, tax risk and corporate governance as well as alternate dispute resolution and litigation across all taxes, including State taxes. Sarah acts for multinational enterprises, ASX listed companies, large corporates, leading financial institutions, private groups and high net wealth individuals as well as previously for the Commissioner of Taxation across all industries. Sarah is one of the few tax practitioners in Australia with experience in managing and resolving multi-jurisdictional disputes by international arbitration and complex international regulatory investigations (across Australia, New Zealand, Vanuatu, Singapore, Hong Kong and the United Kingdom). Sarah is recognized in Best Lawyers – Tax Law 2017 and 2018; Who’s Who Legal – Corporate Tax (Tax Controversy) – 2016, 2017; International Tax Review – World Tax Rankings 2015, 2016, 2017; Chambers and Partners – Asia Pacific and Legal 500 Asia Pacific and is also a Harvard trained negotiator. - Current at 23 January 2018
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Current at November 2008
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