Understanding and managing tax uncertainty: part 2
Published Date: 18 Aug 2025
Part 2 of this article discusses how advisers may assist their clients in managing tax uncertainty in practice, while also managing their own professional regulatory risks along the way. Part 1 discussed the definition of “tax uncertainty”, what may create tax uncertainty, the risks of tax uncertainty, and methods for identifying an uncertain tax position in client circumstances. In this second article, the authors look at the role of the elements of effective tax governance in managing uncertain positions, when and when not to use private rulings to clarify tax uncertainty, the pros and cons of litigation on private rulings or assessments to deal with tax uncertainty, how best to engage with the ATO in trying to manage tax uncertainty, and when settlements might play a part in resolving tax uncertainty, where the parties can agree to do so.
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Details
- Published By: Bruce Collins CTA, Amanda Guruge CTA
- Published On:18 Aug 2025
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