Internal and external expertise

The diversity of industries and the types of entities used in business bring a wide range of tax issues to our attention. These issues range from simple to complex, and cover many areas of tax law.

Although our officers generally have a sound understanding of the laws relevant to information gathering for their case work, they are able to get assistance from advisers for more complex cases.

The provision of general legal advice on issues relating to access and information gathering resides with our General Counsel. Other advisers include officers in our various technical areas and networks. When required, our officers will seek early engagement with an adviser to assist in identifying the information required and how to gather it effectively.

To help ensure our formal powers are used lawfully and appropriately, our officers may engage these advisers at any time and may consult with them before they start to gather information. Our officers will generally consult a General Counsel adviser before using our formal powers in cases of access without notice, complex challenges to legal professional privilege claims and the limited number of cases where we may need to look at a document that may be privileged.

At times, we may also seek expert advice from external subject or industry specialists. In addition, we would consider engaging external counsel as early as possible in situations where:

• the matter is clearly significant or complex
• there is uncertainty relating to our view of the law
• there have been difficulties obtaining information in the past
• we are having problems gathering information in an ongoing matter.

Figure 2 Our collective capability