Published Date: 9 Jul 2025
Providing clients with the best service while protecting your own livelihood can be difficult when there is tax uncertainty. It is important for all tax advisers to understand tax uncertainty and to then learn how to manage tax uncertainty. Tax uncertainty impacts all taxpayers — large and small, private, and not-for-profit. Part 1 of this article guides tax advisers on how to identify tax uncertainty and why it is important. The article covers the tax uncertainty model, risks of tax uncertainty, and assessing what is an uncertain tax position. It examines the key definition of what constitutes a “reasonably arguable position”, before reviewing the “reportable tax position” concept and the ATO schedule requirements, and then considers some of the ATO products that seek to enlighten practitioners and taxpayers on areas of uncertainty. Part 2 of the article works through some of the practical issues in managing cases involving identified tax uncertainty.
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