There are relatively higher rates of dispute in these 2 segments due to factors such as:
- the complexity of large commercial or international transactions, where there can be disagreement about how the law applies in the circumstances
- taxpayers and their advisers have a greater awareness of and familiarity with dispute processes
- taxpayers may lodge an objection to adjust their original claims, particularly where there is a court decision in another taxpayer's favour and they have similar circumstances.
Objections do not always reflect disagreement with the ATO's analysis. It is not uncommon that taxpayers provide new legal arguments and additional information. Objections are also used as a pathway to other dispute resolution processes, such as the Mutual Agreement Procedures under our Double Tax Agreements with other countries.