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Challenges with the ATO’s evolving approach to information gathering presentation


This presentation covers:

  • methods of gathering information from taxpayers
  • practical challenges faced by the ATO and taxpayers in complying with information requests
  • potential outcomes of non-compliance.

Author profiles

Fiona Knight
Fiona is an Assistant Commissioner at the Australian Taxation Office. She has 19 years’ experience in taxation law and currently works in the Tax Counsel Network providing advice on the most complex tax technical issues, including audits, rulings, litigation and legislative changes. She is a member of the General Anti-Avoidance Rules (GAAR) Panel. Previously she has worked in the Large Business & International and Litigation areas of the ATO. Fiona is admitted to practise as a Barrister and Solicitor of the Supreme Court of Victoria and is admitted as a Chartered Tax Adviser by The Tax Institute. She was a finalist in the Institute of Public Administration Australia 2010 Young Public Sector Leader Awards and has lectured at the Leo Cussen Institute in income tax and advanced capital gains tax.
Angelina Lagana CTA
Angelina is a Tax Dispute Resolution and Controversy Partner in KPMG Law and has over 18 years’ experience specialising in tax controversy and dispute resolution. Angelina has represented high wealth individuals, corporations and multinationals subject to Australian Taxation Office (ATO) Reviews and Audits, including the early assessment of contemporaneous evidence, audit strategy, and conducting successful negotiations leading to satisfactory resolution of ATO inquiries, risk reviews and audits. Angelina assists and advises her clients throughout all stages of an ATO inquiry from risk reviews, audits, objections, alternative dispute resolution and litigation. Angelina has significant experience in acting as instructing solicitor in large scale litigation in the Federal Court and Administrative Appeals tribunal, both on behalf of large corporates, private clients, and on behalf of the Commissioner of Taxation. This provides Angelina with a unique insight and perspective on how to prepare for and manage a taxpayers dealings with the ATO and other revenue authorities such a the State Revenue Office (SRO) and AusIndustry. Angelina advises on effectively preparing for and resolving disputes with the ATO, the preparation of evidence, application of legal professional privilege, freedom of information and the ATO Access powers (including onshore and offshore formal information gathering processes that occur during ATO risk reviews and audits). - Current at 06 February 2018


This was presented at 34th National Convention .

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Individual sessions

Challenges with the ATO’s evolving approach to information gathering

Author(s):  Fiona Knight,  Angelina Lagana

Materials from this session:

Australia’s response to the OECD/G20 BEPS Project – What is the reality?

Author(s):  Peter MADDEN

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Tax and technology: Automation, the digital economy and single touch payroll

Author(s):  Robyn Jacobson,  Colin Walker

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Transfer pricing update

Author(s):  Cameron Smith

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Reconstructing financing transactions: A focus on the debt and equity rules, Division 815 and thin capitalisation

Author(s):  Stuart Landsberg,  Rasool Tariq

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Further details about this event:


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