A.3.1 The Second Commissioner's letter in response to the review is reproduced on pages 127 and 128. The detailed responses are set out after the Second Commissioner's letter, with the Inspector-General's comments on these responses also included.


Australian Government - Australian Taxation Office crest

SECOND COMMISSIONER OF TAXATION

Mr David Vos
Inspector-General of Taxation
Level 19, 50 Bridge Street
Sydney NSW 2001

Dear David

FOLLOW UP REVIEW INTO IMPLEMENTATION OF AGREED RECOMMENDATIONS

Thank you for your letter of 26 October 2007 providing your final draft report on the above review.

The Tax Office commitment to improving the administration of the tax system has been demonstrated in the outcome of this review which, as you note, finds that the vast majority (62 of 65) of agreed recommendations from the six Inspector-General of Taxation reports prepared between August 2003 and May 2006 have been either fully implemented or significant progress has been made towards implementation. Your report also notes at paragraph 2.1 that even the few agreed recommendations that you have assessed as not implemented have all been progressed to some extent.

It is pleasing that your report acknowledges the cooperation and willingness of tax officials to work collaboratively with your officers to clarify expectations and make improvements throughout the review process. Our commitment to working with external scrutineers to achieve our shared goal of improving the tax administration system is demonstrated by the 'very positive' outcome of this report. We appreciate your acknowledgement in this regard.

There is, of course, always room for improvement and we would like to draw to your attention the focus the Tax Office Executive and Audit Committee has placed this year on the timely implementation of external scrutineer recommendations. For example:

  • National Program Managers have been asked to review governance arrangements, including nominating realistic implementation timeframes;
  • Sub-Plan Chairs have been requested to monitor the level and nature of progress against outstanding recommendations; and
  • an integrity indicator has been developed that will measure and report corporately the progress of all agreed recommendations.

Whilst I would like to draw your attention to both the general and specific comments I have made on chapters three, six, seven and nine in the attachment to this letter, I would also like to take this opportunity to make the following two observations:

Chapter 3: Review of Management of Part IVC Litigation

I welcome your conclusion that all but one (subsidiary recommendation 6.5 where progress is contingent upon another agency) agreed recommendations resulting from this review have been fully or substantively implemented.

Chapter 6: Review into Small Business Debt Collection Practices

You have assessed the two recommendations from this review as not implemented. We appreciate your acknowledgement of the significant challenge associated with implementing key recommendation 1 and the collaborative nature of Tax Office initiatives adopted in response to key recommendation 2, but I would like to refer you to the attachment to this letter which shows the considerable progress made in this area in the last few months.

Thank you for opportunity to comment on your final draft report.

Yours sincerely

[SIGNED]

Bruce Quigley
Second Commissioner Law
26 November 2007


The Inspector-General of Taxation's Review into Implementation of Agreed Recommendations

The Tax Office's detailed response combined with the Inspector-General's comments

Chapter 3 — Review of Tax Office Management of Part IVC Litigation

General comments

A.3.2 The Commissioner welcomed the opportunity to work with the Inspector-General during the review process to establish a better common understanding of the expectations underlying the recommendations and perceived status of the implementation of the recommendations. This enabled the Commissioner to agree, in some instances, to undertake further work to meet these expectations prior to the review being completed. This resulted, as the Inspector-General's analysis in Chapter 3 shows, all but one of the agreed recommendations having been either fully or partly implemented as agreed.

A.3.3 Of the remaining four recommendations that are not yet fully implemented, one (key recommendation 3) has been implemented to the extent it was agreed, although we have since agreed to do further work on this recommendation. The final implementation of three of them (key recommendation 5, subsidiary recommendations 6.2 and 6.5) is contingent upon the actions of another agency.

Key Recommendation 3

Inspector-General's Key Recommendation 3

The Tax Office should introduce risk management techniques to its management of tax litigation issues. It should start this process by defining the scope of the Commissioner's and the Tax Office's legal risk in collaboration with the Australian Government Solicitor (AGS) and counsel engaged by the Tax Office.

Inspector-General's Implementation Status: Partly implemented

The Tax Office has prepared a practice statement that brings together their risk management approach in litigation. However, the practice statement does not introduce any new risk management techniques to its management of tax litigation issues.

The Tax Office has also recently sought and now received advice from the AGS regarding the scope of the Commissioner and the Tax Office's legal risk. The Tax Office is currently in the process of considering recommendations for improvement by the AGS.

Tax Office Response to Key Recommendation 3

A.3.4 The Tax Office responded to this review recommendation as follows:191

  • We will review our current practices with this recommendation in mind.
  • All litigation cases are risk assessed at the commencement of litigation and risks are reviewed throughout the course of litigation. The Tax Office has a practice statement that outlines the process for risk assessment in litigation — see PSLA 2005/22.
  • Although that practice statement focuses on priority technical issues (PTI) it makes it clear that, whether or not a case is linked to a priority technical issue, business lines must adhere to their own governance practices to ensure decision making is made at the appropriate level. Moreover, the Tax Office's Code of Settlement Practice provides guidance for Tax Office staff considering settlement of disputes, which also encapsulates risk management concepts. Where counsel and the AGS are involved in litigation, they assist in identifying legal risks to the Commissioner throughout the course of litigation.
  • Nevertheless we will review our current practices to ensure that the proposed litigation practice statement clearly articulates how we approach litigation in cases which do not involve PTIs, including a better articulation of the factors that underlie our risk management approach.

A.3.5 We have reviewed our risk management techniques, modified many current practices, as evidenced in this review, and incorporated many of those practices in practice statements that have issued following the review. We ensured that proposed practice statements would clearly articulate the approach in litigation for matters that were not a PTI, including a better articulation of factors that underlie our risk management approach.

A.3.6 Importantly, as a result of the review, we issued practice statement PS LA 2007/16 'Risk Management in Litigation' which captured the risk management practices already in place and set them out in a more structured way.

A.3.7 Paragraph 3.32 of the Inspector-General's report states that PS LA 2007/16 lacks consideration of the commercial and business environments that taxpayers operate within. This suggests that in responding to litigation brought by a taxpayer, the Commissioner should identify the risks to the taxpayer, as opposed to the risks to the Commissioner. The Inspector General also takes the position that risk management should include the techniques used by the ordinary taxpayer. It would seem that this is a reference to the Inspector General's view that the Commissioner should only continue with a disputed tax case where the expected monetary benefit from the case exceeds the costs incurred in litigating the case192.As explained in our response to the 2006 Report, we cannot agree with that view, as a general proposition193.

A.3.8 Although the Commissioner's approach to risk is generally different to that of taxpayers, given the Commissioner's interest in the administration of the tax system generally, we believe that two important aspects of the Commissioner's administration provide some balance. Firstly the code of settlement practice provides scope for mutual resolution of disputes, in the interests of good administration, where important points of principle will not be compromised. Secondly, the Tax Office's Test Case program, which broadly meets the taxpayer's costs of litigation in important cases, provides some balance between the Commissioner's desire to test areas of contention in the law and the taxpayer's interest in a commercial outcome.

A.3.9 We acknowledge the comments made by the Inspector General in relation to Behm194 Recommendation 3.2.1, which lies behind the Key Recommendation.

A.3.10 We agree that we did not at that time obtain a formal advice on the scope of the Commissioner's legal risk, and given the Inspector General's views, we agreed during this review as noted by the Inspector General (paragraph 3.31), to formally obtain from AGS a more complete and focussed advice on the scope of the Commissioner's legal risk. We have received that advice and will now have that advice reviewed, and if necessary updated and finalised by counsel, in line with the recommendations. This will deal decisively with Behm recommendation 3.2.1 and the related residual issue in Key Recommendation 3. We will consider whether any existing documents require updating once the advice is finalised.

Inspector-General's comments on Tax Office response

A.3.11 The Tax Office response incorrectly assumes that at paragraph 3.32 the Inspector-General is suggesting that in responding to litigation brought by a taxpayer, the Commissioner should identify the risks to the taxpayer, as opposed to the risks to the Commissioner. Paragraph 3.32 is simply saying that the Tax Office needs to consider risk management from the perspective of the commercial and business environments that taxpayers operate within.

A.3.12 The Tax Office response also incorrectly assumes that the Inspector-General is suggesting that the Commissioner should continue with a disputed tax case only where the expected monetary benefit from the case exceeds the costs incurred in litigating the case. Reference should be made to paragraph 5.57 of the Inspector-General's 2006 review195 which clearly states that in assessing litigation risk the Tax Office should do so in the same manner as a normal litigant.

A.3.13 The Inspector-General notes that the Tax Office has now obtained formal advice from the AGS regarding the scope of the Commissioner's legal risk and has undertaken to have the advice reviewed, and if necessary, updated and finalised by counsel. Furthermore, the Tax Office has undertaken to update any existing documents once the advice is finalised.

Key Recommendation 4

Inspector-General's Key Recommendation 4

The formal test case program (defined as the program under which a taxpayer makes a formal application for test case funding in accordance with funding criteria that have been publicised by the Tax Office) which is designed to fund cases which will clarify the law by establishing new legal principles should remain but new arrangements for the management of the test case program are needed. Precedents for an appropriate structure which deliver independence without being overly bureaucratic could be the existing Tax Agents' Boards or the Board of Taxation.

Inspector-General's Implementation Status: Partly implemented

In August 2006 the previous government introduced the Taxation Test Case Funding Review Panel to review unsuccessful applications for test case funding. While this does not represent a new and independent management process for the whole test case program, it provides an avenue for more independent review and therefore addresses the recommendation. The Inspector-General is concerned that there is no published information available for the general public about either the role or the activities of the Review Panel.

Tax Office Response to Key Recommendation 4

A.3.14 Whilst the Inspector-General has noted that this recommendation has been implemented through the previous government's decision to establish the Taxation Test Case Funding Review Panel in August 2006, he is still concerned that there is no published information available for the general public about either the role or the activities of this Review Panel. That is primarily a responsibility for Treasury. Nonetheless, a revised Test Case Booklet will be published that will incorporate the arrangements put into place by Treasury. This booklet is also awaiting advice from Treasury in relation to the issues set out in Key Recommendation 5.

Inspector-General's comments on Tax Office response

A.3.15 The Tax Office has undertaken to prepare a revised Test Case Booklet that will include information about the role and activities of the Taxation Test Case Funding Review Panel. This will substantially address the Inspector-General's residual concerns regarding implementation of this recommendation.

Key Recommendation 5 and Subsidiary Recommendation 6.2

Inspector-General's Key Recommendation 5

The Tax Office should fund taxpayers' expenses in defending the case in all cases where the Tax Office has been unsuccessful at any stage of litigation, a decision is made to appeal the relevant decision and it is fair and in the public interest for the Tax Office to fund the taxpayer's expenses. The Tax Office should develop and publicise appropriate guidelines for the funding of such cases.

Inspector-General's implementation status: Partly implemented

The Tax Office continues to work with the Treasury and the Attorney-General's Department in the development of guidelines for funding respondents' costs in appeals against court and tribunal decisions adverse to the Commissioner.

Inspector-General's Subsidiary Recommendation 6.2

The Tax Office should take steps to clearly notify the community of the existence of funding arrangements for cases which fall outside the formal test case program and the other rules for funding Tax Office appeals against AAT decisions and appeals to the High Court. It should notify the community of the types of cases that it will fund in this way and of the circumstances in which this funding has been and will be used by the Tax Office

Inspector-General's implementation status: Partly implemented

The Tax Office continues to work with the Treasury and the Attorney-General's Department to review funding policy and to prepare revised guidelines. The Tax Office has undertaken to revise its 'Test Case Litigation Program' booklet to incorporate the level of information required under the subsidiary recommendation.

Tax Office Response to Key Recommendation 5 and Subsidiary Recommendation 6.2

A.3.16 We will continue to work with the Treasury and the Attorney-General's Department to implement these recommendations.

Subsidiary Recommendation 6.5

Inspector-General's Subsidiary Recommendation 6.5

The Inspector-General recommends that the current exclusion of tax avoidance cases from the AAT adverse appeal funding arrangements be removed. The Tax Office should develop guidelines which allow funding for the costs of an appeal to be provided to taxpayers in cases involving alleged tax avoidance where the AAT determines that there was no such tax avoidance, the taxpayer wins their case and the Tax Office appeals against that AAT case to the Federal Court.

Inspector-General's implementation status: Not implemented

The Tax Office continues to work with the Treasury and the Attorney-General's Department to review funding policy and to prepare revised guidelines.

The above Tax Office position does not alter its current view that cases involving tax avoidance will generally not be funded. The Inspector-General maintains its view that where a taxpayer has been successful in a matter before the AAT which included testing of the issue of tax avoidance, adverse decision funding should not be denied where the Tax Office decides to appeal. Unless the new guidelines clearly adopt the position recommended by the Inspector-General, the Tax Office approach to this issue will continue to be unfair.

Tax Office Response to Subsidiary Recommendation 6.5

A.3.17 The Tax Office response to subsidiary recommendation 6.5 was 'tax avoidance cases will not be automatically excluded where it is fair and in the public interest to fund an appeal.'

A.3.18 The revised Test Case Booklet will reflect that cases involving tax avoidance schemes or attempts to gain a benefit clearly not intended by the law will not be automatically declined where it is fair and in the public interest for them to be funded. The Inspector-General is aware that we have previously funded cases involving an application of tax avoidance principles. In those circumstances it was regarded as being in the public interest to do so.

Inspector-General's comments on Tax Office response

A.3.19 The above Tax Office position does not alter its current view that cases involving tax avoidance will generally not be funded. The Inspector-General maintains its view that where a taxpayer has been successful in a matter before the AAT which included testing of the issue of tax avoidance, adverse decision funding should not be denied where the Tax Office decides to appeal. Unless the new guidelines clearly adopt the position recommended by the Inspector-General, the Tax Office approach to this issue will continue to be unfair.

Chapter 6 — Review into the Tax Office's Small Business Debt Collection Practices

Key Recommendation 1

Inspector-General's Key Recommendation 1

The Inspector-General recommends that the Tax Office addresses issues of competitive disadvantage by distinguishing collection approaches between:

  • those small business tax debtors that want to comply with their payment obligations but need short term assistance to do so; and
  • those small business tax debtors that are either incapable of meeting tax payment obligations within a relatively short time frame or are in serial default.

Inspector-General's implementation status: Not implemented

The Tax Office is in a prolonged process of developing an automated risk profiling capability that will enable treatment strategies to be based on the risk profile of a debt case.

The key design features of the proposed analytics model appear to be broadly in line with the Inspector-General's recommendation. It is apparent that the proposed model will need to perform more detailed analysis to effectively distinguish collection processes between compliant and non-compliant small business taxpayers.

The likely effectiveness of the proposed capability cannot currently be assessed. The model is not yet operational. No finalisation date for this initiative has been provided.

Pending successful implementation of the new capability, the Tax Office remains reliant upon existing capability that does not differentiate to the level required by the recommendation.

After two years, this recommendation is not implemented. However, the challenge of building a system with the level of sophistication needed to deliver the required capability is significant. The Inspector-General is satisfied that the Tax Office is attempting to meet this challenge.

Tax Office Response to Key Recommendation 1

A.3.20 The Tax Office agrees with the Inspector-General's comments that building the systems with the level of sophistication needed to deliver the required capability (Operational Analytics) will be challenging. Notwithstanding, the Tax Office is meeting this challenge. Since the Tax Office's Minute to the Inspector-General dated 28 February 2007 we have made considerable progress in this area.

Debt Analytics Models (paragraphs 6.11 — 6.13)

  • The Tax Office has made further progress to both the development and implementation of debt analytics models.
  • Analytics allows the Tax Office to transform qualitative and qualitative data and information into knowledge to help differentiate taxpayers and to support business decision making.
  • Pilots on the use of analytics in building risk rating models have been ongoing since November 2005.
  • An Expert risk model has been operational in the Debt legals environment since July 2006.
  • Propensity to Pay and Capacity to Pay models have been undergoing further testing and a gradual rollout across the outbound contact debt collection environment commenced in August 2007.

Opportunities to change existing practices (paragraphs 6.15 — 6.16)

  • The Tax Office has now fully implemented and integrated into its debt collection processes the following changes:
    • remission of small residual general interest charge ('GIC') on completed promises to pay;
    • accepting GIC remission requests to the value of $1,500 over the phone;
    • simpler and more flexible guidelines for payment arrangement proposals including those under $25,000;
    • removing the need for taxpayers to lodge outstanding returns before the Tax Office agrees to enter into a payment arrangement;
    • the development of key guiding principles, which reflect the Tax Office's; and
    • organisational values as outlined in the Strategic Statement.

A.3.21 These initiatives support the Tax Office's intent to deliver an improved and differentiated client experience.

A.3.22 The Business Perceptions Survey conducted in May 2007 indicated that 64 per cent of businesses surveyed agreed that the Tax Office takes into account their circumstances when making decisions. This is up from 50 per cent for the previous survey, which was conducted in November 2006.

A.3.23 Surveys are conducted on behalf of the Tax Office by Eureka Strategic Research on a regular basis, involving samples of around 1,500 micro businesses and small to medium enterprises.

Inspector-General's comments on Tax Office response

A.3.24 The Inspector-General acknowledges the further progress that the Tax Office has made in relation to the debt analytics models as well as with the changes identified in paragraph 6.15. The Inspector-General has not reviewed the implementation of these changes because of their recent introduction. As noted in the Tax Office response, there is still more work ahead including the continuing development of the analytics models.196

Key Recommendation 2

Inspector-General's Key Recommendation 2

The Inspector-General recommends that the Tax Office works with the small business sector, and their representatives, to develop new administrative approaches to actively assist small businesses to better manage cash flows, if necessary, to meet tax liabilities as and when they fall due.

Inspector-General's implementation status: Not implemented

The continued improvement, in co-operation with the small business sector, of the range of cash flow management tools and education strategies aimed at helping small business to improve their approaches is very positive.

The Tax Office has not provided evidence that it has considered or developed any changes to its own administrative approaches that would assist business to manage cash flows and to meet tax obligations as and when they fall due. There has been no indication of any new approach such as occurred with the taxi industry initiative. The Tax Office has not followed-on from their response to the original Inspector-General report.

The Tax Office should have done more over the two years since the recommendation was accepted to consider if it could change its own approaches. The recommendation has therefore not been implemented.

Tax Office Response to Key Recommendation 2

A.3.25 Paragraphs 6.18 to 6.19 do not seem to note the Tax Office's response on the progress of this recommendation, contained in our Minute to the Inspector-General dated 28 February 2007 and in any event, the Tax Office's ongoing commitment to small business is demonstrated by recent additional initiatives.

Small Business Assistance Program (SBAP)

  • In delivering a range of assistance programs to small business, the Tax Office has launched the Small Business Assistance Program (SBAP). The program provides a co-ordinated assistance approach tailored to meet the needs of small business at particular stages of their business lifecycles and designed to make it as easy as possible for businesses to comply with their tax obligations.
  • This program identifies how we currently assist small business and the key gaps in our service delivery from which pilots will be conducted to improve our service levels.
  • Following the recognition by the Inspector-General of the taxi industry activity payment card as one approach in assisting small business with cash flow, the SBAP is now considering implementation of a pilot to commence from late November 2007 to determine the feasibility and benefits of further expansion of the card to other industries.
  • The target population for this pilot is within the micro business segment and will draw on taxpayers in the four industries that have the highest representation in the available population.

Debtor Research

  • In recognising that small businesses account for the majority of the Tax Office's collectable debt, we are currently undertaking Debtor research at both the tactical and strategic level. We have adopted a multi-faceted research approach, with the aim of identifying characteristics of tax debtors and gaining a better understanding of the factors shaping the incidence of tax debt among small businesses.
  • In particular, the research will broadly investigate:
    • how macro-economic factors influence small business tax debt;
    • how changes in economic conditions impact on the level of small business tax debt;
    • how small businesses manage their cash flows and what systems and strategies they use to monitor their cash flows;
    • how small businesses manage their overall debts;
    • where the Tax Office sits in terms of priority of payment;
    • perceptions of the Tax Office prior to, and after, incurring the debt; and
    • the effectiveness of the Tax Office's current strategies in assisting taxpayers to clear their debt.
  • Activities underway as part of the project include:
    • engaged external consultant, Eureka Strategic Research, who have completed initial qualitative research. We expect to commence the quantitative component in February 2008. This will involve a large number of interviews with small business taxpayers, some with a tax debt and others who do not have a tax debt.
    • engaged academics based at the University of Queensland to undertake a scoping study to develop a research framework, and
    • commenced analysis of information provided from tax administrations (that is UK/USA) that attended an International Debt Collections Workshop held in Brisbane, Queensland, April 2007.
  • The Tax Office expects to gain a better understanding of the factors influencing the decision-making behaviour of small businesses with regards to tax obligations. The findings of the project may also be used to enhance the Tax Office's taxpayer education, communication and collection strategies.

Inspector-General's comments on Tax Office response

A.3.26 The Inspector-General acknowledges the continuing efforts of the Tax Office to develop initiatives aimed at assisting the small business sector to better manage cash flows and so meet their tax liabilities as and when they fall due. However, the Tax Office response suggests that it is still primarily focussed on small business approaches and has still not considered or developed any changes to its own administrative approaches that would in turn assist small business to manage cash flows and to meet tax obligations as and when they fall due. Hopefully proposals will emerge from the research project that the Tax Office now has underway. The Tax Office consideration of a pilot expansion of the taxi industry activity payment card is welcomed.

Inspector-General's Paragraph 6.24

6.24 The Inspector-General considers that a range of possibilities exists for new Tax Office administrative approaches that should by now have been considered and developed by the Tax Office, working with the small business sector. Examples of these possibilities include:

  • Extending the kind of thinking and approaches used in the taxi industry to other industries or sectors.
  • Working with the banking sector to develop a 'withholding facility' for selected industry groups which requires businesses to deposit regular amounts into the facility. Once deposited, these amounts would in turn be directed towards tax liabilities. Related possibilities include facilitating and encouraging the use of BPAY facilities towards the same end.
  • Working with the small business sector to conduct research into the cash flow cycles and terms of trade of particular industries as a basis for both considering administrative changes (for example by re-aligning payment due dates with periods when funds are available) and for improved understanding when managing debt cases.

Tax Office Response to Paragraph 6.24

A.3.27 In relation to the Inspector-General's suggestion of working with the banking sector to develop a withholding facility, the Tax Office confirms that many of the major financial institutions offer their customers a GST offset account. These accounts enable customers to keep their GST outlays separate from their daily business banking and allow money to be remitted directly to the Tax Office via a number of payment methods, such as phone banking or BPAY.

Chapter 7 — Review into the Tax Office Administration of GST Refunds Resulting from the Lodgement of Credit BASs

General comments

A.3.28 The Tax Office welcomes the Inspector-General of Taxation's confirmation of the substantive implementation of recommendations arising from the Review into Tax Office Administration of GST Refunds resulting from lodgement of credit BASs. As noted in the report, agreement has been reached on what is needed to finalise the one remaining partially implemented sub-recommendation.

Chapter 9 — Other matters

Inspector-General's Paragraphs 9.3 and 9.4

9.3 Representatives from the IAB (including the Director of Governance) meet bi-monthly with the senior Tax Office staff from the business lines to discuss the above mentioned reporting process. The Tax Office has advised the Inspector-General that a project197 is being designed to improve and streamline the reporting process. In particular, this project will be looking at the level of information provided to the IAB and ultimately to the Audit Committee.

9.4 Copies of the above mentioned quarterly Audit Committee reports provided to the Inspector-General were patchy and contained very limited analysis. The Inspector-General considers that monitoring at the level of the Audit Committee is appropriate; but hopes that the above mentioned IAB project will increase the level of information included in the reports beyond the current numerical exception data.

Tax Office Response to Paragraphs 9.3 and 9.4

A.3.29 As noted by the Inspector-General, the Tax Office is committed to implementing agreed outcomes from external scrutineer reviews. In line with this commitment Internal Audit Branch (IAB) has initiated the following improvements to our governance processes:

  • incorporating into one report to the Audit Committee, Tax Office progress against the implementation of both external and internal recommendations. Reports to the Audit Committee are provided on a quarterly basis.
  • development of improved functionality of the recommendations database to enable more detailed and informed analysis of data and subsequent reporting
  • introduction, from July 1 2007, of an external scrutineer integrity indicator that measures the timeliness of implementing agreed outcomes, both at the corporate and business/service line level.

A.3.30 These initiatives will provide a more effective and efficient process and accountability mechanism for monitoring the implementation of external scrutineer recommendations.


191 Review of Tax Office Management of Part IVC Litigation (2006) — Inspector-General of Taxation (at 2.56).

192 Ibid (at 5.57).

193 Ibid (at A3.c.10).

194 In 2003 a review of the management of the risks associated with the Tax Office's conduct of litigation on Part IVC matters was conducted by Mr Allan Behm, Director of Knowledge Pond Pty Ltd, with technical assistance provided by The Value Creation Group Pty Ltd. The report from this review was finalised in September 2003.

195 Review of Tax Office Management of Part IVC Litigation (2006) — Inspector-General of Taxation.

196 Including the two predictive scoring approaches — the propensity to pay score and the capacity to pay score.

197 This project is an IAB initiative — conference with the Director of Governance, IAB, 17 October 2007.