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Dispute Resolution Working Group key messages 5 December 2023

Key topics discussed at the Dispute Resolution Working Group meeting 5 December 2023.

Published 26 February 2024

Lodge and pay reset

The Australian Taxation Office (ATO) is focused on addressing unpaid tax debt, in accordance with the Corporate Plan 23–24. The increase in the collectible debt book post COVID-19 requires the ATO to shift behaviour back to an engagement and a payment culture, to ensure fairness to those who pay on time. The focus areas include unpaid superannuation guarantee surcharge, refund fraud, audit programs, aged and high value tax debts and employers with new debts. For some clients, firmer action will be required, for example the imposition of director penalties and disclosure of tax debts. The ATO will continue to provide support to clients who need it with options such as payment plans, deferrals and remission of penalty and interest. Clients who contact the ATO early will be best placed to discuss such options.

Objection service principles

The ATO has developed objection service principles aligned to the new Taxpayer Charter, that outline staff and client expectations when engaging in the objection process. For staff, these principles include being:

  • client focused
  • fair and reasonable
  • accountable
  • professional.

For clients, these principles focus on:

  • timely engagement
  • being open and transparent
  • preparedness.

The aim is to highlight best practice and a greater understanding of what a client can expect when participating in the objection process. The service principles will be published on in 2024.

Small business independent review expansion

As announced in the May 2023 budget, the ATO will be trialling an 18-month expansion of the Small Business Independent Review (SBIR) service, to businesses with an aggregated turnover between $10 million and $50 million from 1 July 2024. This is part of the government’s new measures aimed at driving collaboration with small business to reduce the time complying with tax obligations. The expansion of the SBIR means that the delivery of the service will expand into the private wealth client experience and has required the ATO to review the current criteria to ensure that it and the associated processes are fit for the expanded program in readiness for commencement in 2024.

Administrative review tribunal

The Australian Government announced in December 2022 that the Administrative Appeals Tribunal would be abolished and replaced by a new federal administrative body; the Administrative Review Tribunal (ART). The ART is expected to commence on 1 July 2024 however the date is dependent on the timing of the enquiry’s report and the consequent passage of the Bills through parliament.

Post meeting comment

On 7 December 2023 the government introduced the Administrative Review Tribunal Bill and the Administrative Review Tribunal (Consequential and Transitional Amendments No.1) Bill (together 'the Bills') into the House of Representatives. The Bills have been referred to the House of Representatives Standing Committee on Social Policy and Legal Affairs to scrutinise the Bills ‘to ensure they achieve the Government’s policy objectives and do not have any unintended consequences'.


Attendee list




Andrew Orme (Chair), Objections and Review


Fiona Knight, Public Groups

Administrative Appeals Tribunal

Michael Abood

Australian Small Business and Family Enterprise Ombudsman

Craig Latham

Chartered Accountants Australian and New Zealand

Ashley King

Chartered Accountants Australian and New Zealand

Karen Liew

CPA Australia

Bill Leung

Law Council of Australia

Angelina Lagana

Law Council of Australia

Hugh Paynter

The Tax Institute

Chris Kinsella

The Tax Institute

Michael Wells

Guest Attendees

Guest attendee list




Alicia Bennett, Objections and Review


Daniel Nesci, Objections and Review


Diana Bedelovski, Objections and Review


Farisha Ali, Objections and Review


Jillian Kitto, Lodge and Pay


Jo Torrens, Objections and Review

National Tax Clinics

Annette Morgan


Apologies list




Michael Morton, Small Business


Rebecca Saint, Public Groups

Corporate Tax Association

Simon Staples