Independent review of the Statement of Audit Position for groups with a turnover greater than $250m

Independent review – the fundamentals

Tax law administration and large business are both challenging environments and as we apply tax law to complex facts, some areas of disagreement may be inevitable. We want to resolve areas of disagreement with you as early and cooperatively as possible.

To support this, we have established an independent review service, where an independent technical officer outside of the audit area reviews the technical merits of your case prior to finalisation of the ATO audit position. The independent review is conducted by a senior officer from our Review and Dispute Resolution business line, which forms part of the Law Design and Practice Group (formerly Law and Practice). This officer will not have been previously involved in the audit and will bring an independent 'fresh set of eyes' to the review.

The position paper process

As part of developing an ATO position, you are given the opportunity to respond to the audit team’s position as disclosed in the Audit Position Paper.

Areas of disagreement are considered by the audit team when reaching their Statement of Audit Position which is then communicated to you.

If you disagree with some or all of the Statement of Audit Position you may request an independent review.

How it will work

Requesting an independent review

From 1 July 2014 you can request an independent review if your turnover or income is greater than $250 million and you have received a Statement of Audit Position regarding your income tax, excise, goods and services tax, or other forms of tax.

How long do you have to request an independent review?

You have 10 working days from when you receive our Statement of Audit Position to request an independent review.

How to request an independent review

Your request for an independent review may be emailed to us at There is no required form but your request must clearly specify and outline each area of disagreement with the Statement of Audit Position.

How long does the independent review take?

We will advise you of the independent review recommendations within 60 working days.

    Last modified: 07 Jun 2016QC 26636