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Inspector-General of Taxation report

Ali Noroozi

This will be my last Annual Report as the Inspector-General of Taxation (IGT), marking my tenth and final year of service. Accordingly, I have taken the opportunity to reflect on the evolution of the IGT and our successes during my tenure.

Prompted by legitimate concerns which were raised regarding the Australian Taxation Office’s (ATO) dealings with taxpayers, the IGT was established in 2003 as an independent adviser who would play an important part in achieving a fairer tax administration system.1 The newly created statutory authority was given strong investigative powers to examine the operation of the system and its advice, in the form of ‘reports’, were required to be publicly released as a means of strengthening its independence as well as enhancing accountability and transparency of the system.2

At the time of the creation of the IGT, there was both a degree of excitement and a level of concern regarding the challenges it would face in seeking to achieve its laudable and lofty aims, particularly given its relative size to that of the ATO. The IGT was the smallest of agencies while the ATO was one of the largest, with vastly greater budget and extraordinary powers that permeate the entire fabric of Australian society – one publication likened it to a David and Goliath battle.3

When I took the reins in 2008, the IGT was becoming established amongst tax professionals as an independent advocate for improvements to the tax system, but in the wake of the 2007 election uncertainty hung over its future.4 The agency was very young and the concept of a specialist, independent scrutineer was not well-appreciated. Since that time, the IGT has become a mainstay in the tax landscape, both domestically and internationally, and has played a major role in delivering improvements and reshaping the administration of the Australian tax system. The office has grown over four times in size and the role has become that of an ombudsman with respect to tax administration. The most significant legacies that I leave behind are the establishment of an efficient and effective complaints handling function within the IGT, the move to creating a separate appeals area within the ATO and a large volume of high quality reports into many aspects of tax administration.

Comprehensive IGT reviews into systemic tax administration issues over the last 10 years have been a major force in prompting significant improvements. During my tenure, we have completed almost 35 reviews canvassing a broad range of issues, including ATO ‘U-turns’, debt collection, tax disputes, rulings, audits, transfer pricing, services and support for tax practitioners, alternative dispute resolution, penalties and taxpayer rights. Enduring benefits from these reviews include increased certainty about prospective application of ATO advice as well as improved dispute resolution by the separation of the objection function from the compliance area5 and the establishment of an in-house facilitation service which saves taxpayers, on average, $50,000.6 Other improvements deliver compliance cost savings for both taxpayers and the ATO – for example, strike rates for compliance activities using cash economy benchmarking has been doubled with fewer small businesses being unnecessarily subjected to audits.7

In addition to the improvements flowing from IGT recommendations, our reviews have become more widely recognised as a source of evidence-based assurance regarding ATO actions.8 Such independent assurance has sometimes been likened to a ‘safety valve’ as it promotes fairness, assuages concerns and builds confidence in the administration of the tax system – critical factors for the efficient and effective operation of a self-assessment tax system. A recent example includes the request from the Senate Economics References Committee for the IGT to investigate the ATO’s fraud control management (the Fraud review) following public concerns relating to allegations of tax fraud, Operation Elbrus,9 which may have been linked to abuse of position by a public official.

The Government has also required the IGT to perform an assurance role. For example I was directed to investigate the ATO’s $756 million program to overhaul its information and communications technology platform.10 More recently, the IGT has also acted promptly to address community concerns, by announcing the Garnishee review11 following a joint Fairfax-ABC Four Corners investigation12 which, amongst other things, brought into question the ATO’s debt collection practices particularly with respect to small businesses.

The Commissioner of Taxation (Commissioner) has also requested the IGT to conduct several reviews in the past.13 More recently, we have accepted a request to conduct a review into the future of the tax profession14 – a forward looking review to address future challenges and realise potential benefits arising from technological, social, policy and regulatory changes ahead.

The broad range and the transparent reporting of the reviews have significantly bolstered community support for the work of the IGT. This has led to increased input into these reviews from small businesses and individual taxpayers, as well as larger taxpayers, tax professionals, professional bodies and industry associations. The result is more comprehensive reports with fulsome and practical outcomes.

Although the IGT reviews have been delivering systemic improvements and fulfilling an assurance role effectively, we were unable to address specific taxpayer issues on a real time basis until 1 May 2015 when the Government transferred the tax complaints handling function to the IGT. The IGT had publicly advocated for such a measure since 2011.15 The IGT’s remit was also broadened to the administrative actions of the Tax Practitioners Board (TPB).16 As a result, the IGT has effectively become the taxation ombudsman.

To date, we have handled over 7,000 complaints from a range of tax professionals and taxpayers including vulnerable individuals and small businesses. In the 2017–18 financial year, the number of complaints increased by 7 per cent and 12 per cent compared with the prior two financial years. Notwithstanding such increase, we continue to acknowledge the vast majority of complaints within two business days and finalise them within 15 business days. The community feedback has been overwhelmingly positive. We have consistently achieved a satisfaction rating of 80 per cent – a testament to the hard work and dedication of our team of tax specialists.

There is a growing awareness of our complaints handling service as reports of its success spreads amongst the community. However, more needs to be done to ensure that taxpayers, particularly the most vulnerable individuals and small businesses, know where to turn when they are most in need of specialist assistance to address their concerns with the actions of the ATO or TPB. Accordingly, we are putting in place a communications strategy to reach more taxpayers. This strategy includes a social media plan which is currently being implemented as well as other measures which we have already put in place such as a quarterly newsletter and delivering presentations to tax professionals and taxpayers in public forums across the country including in regional areas.

Both the complaints handling service and the review function are important for improving tax administration and their co-location in one agency delivers critical synergies. Themes emerging from complaints allow more timely identification and investigation of potential systemic issues. In this financial year alone, insights from complaints data led to two reviews and an own initiative investigation17 being conducted and completed. Analyses of complaints data have also resulted in the identification of opportunities for improvements which the ATO has agreed to implement without the need to conduct reviews (Agreed Business Improvements, ABIs).

Correspondingly, the implementation of recommendations arising from systemic reviews may address many complaints that may otherwise arise. In addition, these reviews provide more detailed understanding of the operation of specific ATO systems and processes for IGT staff, allowing them to better assist taxpayers with their complaints.

Improvements, such as those outlined above, have led to greater recognition of the importance of the IGT’s role in improving the tax administration system. For example, the House of Representatives Standing Committee on Tax and Revenue in its 2016 Inquiry into the External Scrutiny of the Australian Taxation Office confirmed that the quality of IGT work had improved ATO operations, generated strong support amongst stakeholders and provided ‘a good return on investment for Australia’ which ‘flows directly to the ATO, and indirectly to Government, the Parliament, and Australian businesses and individuals’.18

More broadly, during my tenure, a trend has been emerging to bolster accountability in complex areas of public administration by creating more independent and specialist ombudsmen or Inspectors-General. In marking this trend, I had the pleasure to host the inaugural meeting of Australia’s Inspectors-General, together with their Deputies. Internationally, there is also an increase in the number of independent specialist scrutineers of revenue authorities.19

The IGT has also made its mark in the international tax community, particularly in taxpayer rights circles20 – for example, the IGT was invited to present and provide insights at taxpayer rights forums in Latin America, Europe and New Zealand.21 In addition to sharing our knowledge and expertise, we also benefit immensely from such interaction as we gain fresh ideas and learn from overseas experience. Such learnings have led to recommendations for improvements in our reviews.22

Since the transfer of the complaints handling function in 2015, the IGT has also been involved in the international ombudsmen community and public-private sector complaints handling circles.23

As set out above, there have been significant achievements over the last ten years. However, such success and greater awareness of the IGT are increasingly presenting challenges too. For example, if the number and complexity of the complaints continue to grow, or accelerate at a more rapid rate, we may not be able to meet our service standards and the number of broader or systemic reviews conducted may be impacted.

I am proud to leave the IGT in a very strong position. Perhaps, my greatest achievement is the firm establishment of the IGT as a trusted, independent and specialist scrutineer who has an integral role in improving the tax administration system for all Australians. These accomplishments would not have been possible without the support and confidence of the tax profession in the IGT.

I am also indebted to my staff who have worked tirelessly, in the face of considerable challenges, to fulfil our goals. Working with them has been the most rewarding part of my role.

Completed reviews

As at 30 June 2018, three reviews were finalised, namely the PAYG instalments review, the GST refunds review and the Fraud review.

Review into Aspects of the Pay As You Go Instalments System

The report of PAYG instalments review was publicly released on 23 January 2018 and was our first review undertaken in response to insights drawn from our complaints handling service. The review had also received stakeholder support during consultation on the IGT work program.

A key focus of this review was the lack of individual taxpayers’ awareness and understanding of the PAYG instalments system. They appeared to be unclear as to why they had been entered into the system, its requirements and exemptions, its interaction with the annual income tax system and the support tools available to them. Accordingly, the IGT had recommended a number of improvements to the ATO’s taxpayer communication and guidance materials as well as internal staff education and support.

The major underlying source of stakeholders’ concerns arose from confusion caused by the interaction between the ATO’s accounting systems that resulted in administrative issues including, the non-receipt of ATO communications and unnecessary debt collection action. Recommendation was made for the ATO, as a longer term goal, to consider using a single integrated accounting system for administering the income tax and PAYG instalments regimes. In the interim, a number of additional recommendations were made and aimed at improving the ATO’s processes.

The review also examined stakeholders’ concerns regarding the ATO’s criteria for entering individuals into the PAYG instalments system, administration of penalties and interest as well as the inclusion of statutory income in calculating the instalment rate. Overall, the IGT had made seven recommendations (comprising 22 parts) of which the ATO agreed in full with six recommendations and in part with the other (or agreement with 21 out of 22 parts).

Review into GST Refunds

This review was also prompted by insights drawn from our complaints handling service and supported by stakeholders during our work program consultation process.

Overall, the IGT found that the ATO’s administration of Goods and Services Tax (GST) refunds operated efficiently with the vast majority of refunds released without being stopped for verification. Moreover, where refunds were stopped, the majority were processed and released within 14 or 28 days.

However, some opportunities for improvement were identified, including developing a framework for continuous improvement of the ATO’s automated risk assessment tools which has been achieving a strike rate of only 26.7 per cent. Furthermore, the IGT had identified that the ATO can streamline its instructions and guidance to staff when interacting with taxpayers, taking into account their circumstances and the adverse financial impacts that delayed refunds can have on their cash flow.

Although fraud risks in the precious metals industry is considered in the Fraud review, this review also specifically examined the ATO’s use of GST refund retention to address such risks. Concerns were raised about the intensity and length of the verification process in such cases. In this regard, there seemed to be a mismatch in expectations between the actions taken by the ATO and taxpayers’ understanding of the process. Accordingly, a recommendation was made to strike a balance between ensuring refunds are released expeditiously in the majority of cases while affording the ATO sufficient time and power to address fraud risks, the seriousness of which has been established.

In total, the IGT made five recommendations (comprising 16 parts) with all of which the ATO agreed in full or in part (11 out of 16 parts).

Review into the ATO’s fraud control management

As mentioned earlier, the Fraud review was commenced at the request of the Senate Economics References Committee following the events relating to Operation Elbrus and allegations of tax fraud that may be linked to abuse of position by a public official. These events had attracted significant media attention and led to calls for an independent review of the ATO’s fraud control framework to ensure that its practices reflect the standards befitting of such a key institution.

The review focused on the ATO’s practices and procedures for the prevention and detection as well as addressing risks of internal fraud. In particular, the review examined key prevention controls including the management of conflicts of interest, senior ATO officer intervention in individual cases and those performing medium to high risk roles in the ATO. The manner in which the ATO’s Fraud Prevention and Internal Investigations unit detects and investigates internal fraud or potential fraud was also considered as well as relevant ATO governance, structure and oversight arrangements.

In addition, the review examined aspects of the ATO’s management of the risks posed by external parties who seek to exploit the tax system and commit fraud against the Commonwealth, in particular those attracting criminal sanctions. In this regard, the IGT examined certain areas and conducted case studies to identify areas for improvement which would complement other recent initiatives aimed at addressing tax and financial crime, for example the Phoenix and Black Economy Taskforces.

The reviewalso incorporated the findings from an IGT ‘own initiative’ investigation into the ATO’s handling of tax evasion referrals that had already been commenced as a result of complaints made by dissatisfied individuals who had made such referrals to the ATO.

As the report of the review contained a recommendation to the Government, it was transmitted to the Minister for Revenue and Financial Services on 22 June 2018 for release within 25 Parliamentary sitting days.24 Accordingly, the findings of the review will be described in more detail in next year’s Annual Report.

Reviews in progress

Review into the Australian Taxation Office’s use of Garnishee Notices

As mentioned earlier, the Garnishee review was commenced on 16 May 2018, following a joint Fairfax-ABC Four Corners investigation25 which brought into question the ATO’s debt collection practices. This investigation included allegations by current and former ATO staff about inappropriate use of ATO powers to issue garnishee notices and extracting payment particularly from small business taxpayers.

This review will examine the above allegations and explore the themes arising from related complaints made to the IGT in recent years. Furthermore, it will consider the ATO’s implementation of specific recommendations made in the 2015 IGT Debt Collection review.26

As at 30 June 2018, this review has been substantially progressed.

Review into the Future of the Tax Profession

The Future of the tax profession review was undertaken in response to a request from the Commissioner as well as concerns raised by stakeholders within the tax profession, particularly tax practitioners, through our complaints handling service and in our other engagements with the tax profession.

In 2014, the IGT undertook a review into the ATO’s services and support for tax practitioners.27 That review largely examined the ATO’s relationship with, and services provided to, tax practitioners. This review is not intended to be a follow up to the 2014 review but, rather, it is forward looking and examines the impending technological, social, policy and regulatory changes which will have a lasting impact on the tax profession. It will seek to address the challenges ahead and realise potential benefits for tax practitioners, the ATO and the TPB as well as the broader community.

As at 30 June 2018, this review is nearing finalisation and its findings will be described in more detail in next year’s Annual Report.

Adoption of IGT recommendations

As mentioned earlier, the reviews and other activities of my office result in both immediate and longer-term improvements. Some of these improvements require administrative action to which the ATO generally responds within each report. Other improvements may require changes to policy and the Government to make legislative changes over time.

In 2017–18, government actions relating to IGT recommendations included:

In 2017–18, the ATO also took actions consistent with IGT recommendations with which it did not initially agree. These actions included:

Complaints handling service

In the 2017–18 financial year, awareness of our complaints handling service has steadily grown as evidenced by an increase in both the number and the complexity of complaint cases that we have received.

We received 2405 complaints during the 2017–18 financial year — approximately a 7 per cent increase from the previous financial year. 88 per cent of these complaints were finalised within the year and work will continue on the remainder in the following year.

The most common issues which were raised in these complaint cases concerned the ATO’s:

Table 1 below shows the proportion of complaints that relate to the above issues as a percentage of total complaints.

Table 1: The five most common issues raised in complaints during 2017–18

Type of issues

Approximate percentage of
all issues raised

Debt collection

24%

Lodgement and processing issues

14%

Outstanding or delayed payments

10%

Audit and review activities

8%

ATO communications

8%

Agreed Business Improvements

As mentioned earlier, opportunities to make broader improvement to the tax administration system may be identified during the investigation of complaint cases without the need to conduct a broader review. ABIs arise when we reach agreement with the ATO or the TPB on how such improvements may be reached without the need for further work by the IGT, such as conducting a review. We track ABIs until they are implemented.

During 2017–18, the ATO had agreed to 12 ABIs and the TPB had agreed to 5. In this financial year, the ATO has implemented 16 ABIs, which include some agreed to in the previous financial year, whilst the TPB has implemented three. Further detail is provided in the Performance Report section of this report.

Feedback on the complaints handling service

We engaged ORIMA Research Pty Ltd (ORIMA) to conduct an independent survey to evaluate the performance of our complaints handling service. The results of this survey have consistently been very positive, indicating a satisfaction rating of 80 per cent with our service and staff. This result includes feedback from complainants who did not achieve their desired outcomes.

During this financial year, we have also implemented an automated telephone survey to gather feedback contemporaneously from complainants who had their concerns addressed in their initial phone call with our office. Forty per cent of such callers participated in the survey and of those who participated, 95 per cent reported satisfaction with the service and would use it again.

More detailed results of the above surveys are provided in the Performance Report section of this report.

Assistance to Parliamentary committees and other government agencies

During 2017–18, we drew upon our complaints handling and review experience to assist parliamentary committees and other government agencies to examine issues that interact with the tax and superannuation systems.

Submission to the Inquiry into the ATO’s 2016-17 Annual Report

On 6 December 2017, the House of Representatives Standing Committee on Tax and Revenue commenced an Inquiry into the ATO’s 2016–17 Annual Report.40 In February 2018, we made a written submission to this Inquiry that identified tax debt collection and reporting, lodgement compliance, dispute resolution as well as services and support for tax practitioners as four key areas which may benefit from further exploration by the Committee.

Submission on proposed Transparency of Business Tax Debt measures

On 11 January 2018, the Minister for Revenue and Financial Services released draft legislation and explanatory materials, for public consultation, which would facilitate the reporting of tax debt information of businesses, who do not effectively engage with the ATO to manage their debts, to registered credit reporting bureaus.41 The materials envisaged a new legislatively enshrined role for the IGT to operate as an independent safeguard that can provide assurance to taxpayers with respect to the administration of these measures.

In February 2018, we made a detailed submission to the Treasury that suggested improvements aimed at ensuring that the measures operate equitably and that the legislative intent is fulfilled. The submission stressed the importance for taxpayers to be informed of their right to lodge a complaint with our office and avail themselves of our services as an independent safeguard. Amongst other things, the submission also commented on the need for further clarification in relation to the provision of notice to taxpayers as well as the need to expand the definition of effective engagement.

Submission to the Treasury Secretary’s Investigation into Small Business Dealings with the ATO

In May 2018, we provided detailed input to assist the Treasury Secretary with his investigation into Small Business Dealings with the ATO. This investigation was prompted by a request from the Minister for Revenue and Financial Services42 following the earlier-mentioned joint Fairfax-ABC Four Corners investigation.

Stakeholder engagement

The tax profession and the broader community

We continued to engage with taxpayers, tax professionals and their representative bodies whilst conducting reviews and through our complaints handling service. In this financial year, the Future of the tax profession review has necessitated more discussions with the tax profession to ensure that the full range of views is captured and appropriately addressed. We have also presented to discussion group meetings of suburban and regionally based tax practitioners as well as those in capital cities.

We also continue to present and participate in a range of events to further raise awareness of the IGT and the services that we provide amongst taxpayers and tax professionals. A full list of IGT speaking engagements is set out in the Performance Report section of this report.

In this financial year, we have also commenced a broader communications strategy to increase awareness of IGT services available to all Australians. The initial stages of this strategy have included the launch of a quarterly newsletter, IGoT! News, which has provided updates on our work such as the progress of our reviews, trends in complaints and other significant aspects of our work.

The next stage of our communications strategy, which commenced in this financial year, is to increase our presence on social media to raise awareness of our services for those who require it the most such as vulnerable individuals and small businesses.

Public sector stakeholders

We continue to engage and consult with the Commonwealth Auditor-General (Auditor-General) and the Commonwealth Ombudsman (Ombudsman) on matters of mutual relevance and interest to minimise potential duplication in our scrutineering activities.

As mentioned earlier, in March 2018, we also hosted a meeting of the Inspectors-General from across Australia to share knowledge and experience, including innovative ideas and best practice models. These meetings will now take place periodically.

We have also continued to develop and foster relationships with other government agencies including the Attorney-General’s Department, the Australian Federal Police, and the Office of the Commonwealth Director of Public Prosecutions. The assistance that we have received from these agencies was particularly useful in conducting the Fraud review. More broadly, interactions with the wider Australian Public Service (APS) ensure that we are aware of the whole-of-government ramifications when identifying improvements to the tax system.

In this financial year we have also fostered closer collaboration with the Australian Small Business and Family Enterprise Ombudsman (ASBFEO) as approximately 25 per cent of complaints lodged with our office are from small businesses. In this financial year, we have also assisted 45 small business taxpayers who were referred to us by the ASBFEO.

Constructive engagement with the ATO and the TPB is crucial whilst the independence of the IGT, as a scrutineer, must be maintained. In this respect, communications between our respective offices continue to be professional, frank, and lead to improvements to the system.

We have also worked closely with the Treasury, who provides us with a number of services and is a partner in many aspects of our core functions, as well as the Minister and her staff.

International stakeholders

We continue to work closely with our counterparts and revenue agencies in the United States, United Kingdom, Canada, New Zealand and Mexico. In this financial year, in conducting current reviews, we have also engaged with revenue agencies in a number of other jurisdictions including the Netherlands, Sweden, Estonia, Finland and Singapore. Such engagement provides useful insights and often results in the development of innovative solutions in the Australian context. We are grateful for the assistance that we have received and will continue to build and foster these relationships in the years to come.

We have also been active on taxpayer rights issues at a global level. We continue to work with the International Bureau of Fiscal Documentation and the International Law Association in this regard as well as presenting and participating in key forums.

We are also involved in the international community of ombudsmen and scrutineers through our membership with International Ombudsman Institute.

Future directions

In the coming months, the IGT will focus on completing the two remaining reviews, namely the Future of the tax profession review and the Garnishee review. A new work program of reviews will have to be developed in the next calendar year — it is appropriate that this task is carried out by my successor.

Looking further ahead, the demand for IGT services is likely to grow as awareness of these services is increasing in the community. It may accelerate further as our communications strategy is fully implemented and bears fruit. Accordingly, in the absence of additional resources, further efficiencies in the manner the IGT work is carried out will have to be sought and difficult decisions may have to be made regarding our service standard in terms of resolution of complaints and the number of broader reviews that may be conducted.

[SIGNED]

Ali Noroozi
Inspector-General of Taxation

Role

Our role is to improve tax administration through the investigation of tax complaints, conducting broader reviews, public reporting and independent advice to Government and its relevant agencies.

Our objectives are to:

Organisational structure

Figure 1: Inspector-General of Taxation executive structure

Outcome and program structure

Figure 2: Outcome and program structure

Appendix 1 – Expenses for outcomes

Appendix 2 – Agency resource statement


1 Senator the Hon Helen Coonan, former Minister for Revenue and Assistant Treasurer, ‘A New Tax Advocate’ (Media Release C62/02, 29 May 2002).

2 See, for example, Senate Economics Legislation Committee, Inquiry into Inspector-General of Taxation Bill 2002 (2002) pp 26–27.

3 Australian Institute of Company Directors, ‘David vs the Taxation Goliath’, Company Director Magazine (October 2003).

4 The amalgamation of the IGT within an existing agency was proposed as part of Labor’s $3 billion Savings Plan announced on 2 March 2007.

5 An improvement made following recommendation 1(b) in the IGT’s The Management of Tax Disputes (2015).

6 In-house facilitation was a service to implement recommendation 3.6 in the IGT’s Review into the ATO’s use of early and alternative dispute resolution (2012); See also Commissioner of Taxation, Annual Report 2016–17 (2017) p 65.

7 The implementation of recommendation 4.1 in the IGT’s Review into the ATO’s use of benchmarking to target the cash economy (2012).

8 See, for, example the IGT’s Review into the ATO’s Change Program (2010) which commenced in 2009 at the direction of the former Minister following substantial public criticism of the ATO’s information and communications technology changes.

9 IGT, ‘Review into the ATO’s fraud control management: Terms of reference’ (2017) <www.igt.gov.au>.

10 IGT, Review into the ATO’s Change Program (2010), chapter 2.

11 IGT, ‘Review into the ATO’s use of Garnishee Notices: Terms of reference’ (2018) <www.igt.gov.au>.

12 Adele Ferguson, Lesley Robinson and Lucy Carter, ‘It’s malicious and it’s vengeful’, ABC news
(7 April 2018) <www.abc.net.au>; ABC, ‘Mongrel bunch of bastards’ 4 Corners (television program aired on 9 April 2018) <www.abc.com.au>.

13 For example, IGT, Review of aspects of the Australian Taxation Office’s administration of private binding rulings (2010) and IGT, Review into the ATO’s use of early and alternative dispute resolution (2012).

14 IGT, ‘Review into the Future of the Tax Profession: Terms of reference’ (2017) <www.igt.gov.au>.

15 IGT, ‘Submission to the Tax Forum’ (October 2011) <www.igt.gov.au>.

16 See Australian Government, Budget Paper No. 2, Part 2: Expense Measures (May 2014).

17 IGT, Review into Aspects of the Pay As You Go Instalments System (2018); IGT, GST Refunds (2018); and IGT, ‘ATO’s management of tax evasion referrals from the community’ (which was subsumed into the Fraud review).

18 House of Representatives Standing Committee on Tax and Revenue, External Scrutiny of the Australian Taxation Office (April 2016), p 31.

19 For example, Canada’s Office of the Taxpayers’ Ombudsman which was created in 2008 and South Africa’s Office of the Tax Ombudsman which was created in 2013.

20 IGT, The Protection of Taxpayer Rights in Australia: Report for the International Bureau of Fiscal Documentation (2015) <www.igt.gov.au>.

21 Ali Noroozi, ‘Developing early warning and intervention systems’ (Presentation at the 3rd International Conference on Taxpayer Rights, The Netherlands, 2–4 May 2018); Ali Noroozi, ‘Taxpayer advocates offices – achievements and challenges’ (Presentation at the Taxpayer Advocacy Offices International Meeting (Defensa del Contribuyente y del Usuario Aduanero), Colombia, 2 August 2018); Ali Noroozi, ‘Taxpayers’ rights, complaints and administration issues from an Australian perspective’ (Presentation at the Tax conference – Taxpayers’ rights and obligations in a changing tax world, New Zealand, 6 September 2018).

22 For example, IGT, The Management of Tax Disputes (2015), p 120.

23 In 2017, the IGT became a member of the International Ombudsman Institute and the Australasian and Pacific Ombudsman Region; IGT staff, ‘Improving Trust – Tax Complaints Case Studies’ (Presentation at 27th Annual Society of Consumer Affairs Professionals (SOCAP) Australia International Symposium, Sydney, 23–25 August 2017).

24 Section 18 of the Inspector-General of Taxation Act 2003.

25 Above n 11 and 12.

26 IGT, Debt Collection (2015).

27 IGT, The Australian Taxation Office’s services and support for tax practitioners (2015).

28 The Board of Taxation, ‘CEO Update — March 2018’ (2018) <www.taxboard.gov.au>.

29 IGT, Review into the ATO’s employer obligations compliance activities (2016).

30 Generally, the TPRS is a system which requires taxpayers in identified industries to report to the ATO payments that they had made to others.

31 Australian Government, Budget 2017–18, Part 2: Expense Measures (May 2017).

32 Australian Government, Budget 2018–19, Budget Measures (May 2018).

33 Above n 29.

34 ATO, Communication to the IGT, 4 December 2017.

35 IGT, Review into aspects of the ATO’s administration of private binding rulings (2010).

36 Nassim Khadem, ‘ATO starts random audits of deductions’, Sydney Morning Herald, 1 March 2018.

37 IGT, Review into aspects of the ATO’s use of compliance risk assessment tools (2014).

38 Commonwealth, Senate Economics Legislation Committee, Proof Committee Hansard – Estimates, 30 May 2018, p 6 (Commissioner of Taxation).

39 Above n 22.

40 House of Representatives Standing Committee on Tax and Revenue, ‘2017 Annual Report of the Australian Taxation Office’ (2017) <www.aph.gov.au>.

41 The Hon Kelly O’Dwyer, Minister for Revenue and Financial Services, ‘Transparency of business tax debts’ (Media Release, 11 January 2018) <www.treasury.gov.au>.

42 Ferguson A and Khadem N, ‘Coalition, Labor to probe ATO over ‘scandalous’ revelations’ Sydney Morning Herald (10 April 2018) which refers to O’Dwyer, K, the Hon Minister for revenue and Financial Services.