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What a large market independent review is

We are committed to resolving disputes early. We offer independent review as part of a suite of dispute resolution services available to taxpayers.

Last updated 30 October 2022

When we offer a review

We offer an independent review if there is demonstrated value for both the taxpayer and us to provide a streamlined and timely pre-assessment review of the Statement of audit position.

We have offered the service to eligible large market taxpayers since 2013. It provides an additional option to achieve an early and fair resolution of your dispute, where you disagree with the audit position.

If you have an audit in progress, we may offer you the opportunity to request an independent review.

Improvements to the service

As part of our review of the service, completed in 2022, we identified and implemented improvements to the independent review process. We found it is more helpful in some types of disputes and refined who is eligible so only appropriate cases and issues are eligible.

We will continue to offer independent review in the majority of large market disputes that don't involve transfer pricing issues. We will only offer it for transfer pricing matters if certain conditions are met. If offered, it will most likely be restricted in scope.

What the review involves

An independent senior officer from our Objections and Review business line, which forms part of the Law Design and Practice Group, will review the facts and technical merits of your audit position before any assessment or amended assessment is issued to you in relation to your audit. This officer won't have had any past involvement with your audit case.