ATO reviews and audits.
Experience that puts you in control from the first request.
Received an ATO request for information, or notice of an audit, interview or access? What you provide now becomes the record the ATO relies on. We advise you, prepare your responses and deal with the ATO on your behalf.
Where your matter stands
I
Contacted by the ATO
Your position set from the first response.
What you provide now becomes the record the ATO relies on. We interrogate the scope of the review or audit, settle the strategy with you and build robust responses on carefully considered evidence. At every stage, you will know your options and what to expect next.
Assistance may include
- Interrogate the ATO’s correspondence and the scope of the enquiry.
- Settle the strategy with you before anything is provided.
- Identify the issues and compile the records that matter.
- Prepare complete, accurate and well-evidenced responses.
- Deal with the ATO on your behalf throughout.
- Make sure you know your options and what to expect at each stage.
Formal notice received
Formal notices, met with a clear strategy.
A formal notice can require you to provide information, attend an interview and give evidence, or produce documents, and failing to comply can be an offence. We settle the strategy for your response, protect privileged material and prepare you thoroughly for any interview.
Assistance may include
- Interrogate the notice, its scope and the time to comply.
- Settle the strategy for your response with you.
- Identify documents protected by legal professional privilege.
- Prepare your response and the production of documents.
- Prepare you for, and attend with you at, any interview.
- Deal with the ATO on your behalf throughout.
Position paper received
Your position clarified and strengthened.
A position paper sets out the ATO’s preliminary view and is the opportunity to respond before the audit is finalised. We interrogate the ATO’s reasoning, settle the strategy with you and build a response on robust evidence that can narrow the issues, correct the facts or resolve the matter.
Assistance may include
- Interrogate the ATO’s reasoning and proposed findings.
- Settle the strategy for your response with you.
- Test the technical position.
- Compile robust evidence to support your position.
- Prepare and lodge a substantiated response.
- Engage with the ATO to narrow or resolve the issues.
Assessment received
An objection built on the correct technical position and robust evidence.
Where the audit has ended in an amended assessment, we build on the audit record, act for you through every stage of the objection and handle all dealings with the Commissioner to enable you to obtain the best possible outcome.
Assistance may include
- Review and interrogate the assessment and the Commissioner’s stated position.
- Discuss and settle the objection strategy.
- Build the technical position and assemble the evidence to substantiate it, drawing on the audit record.
- Prepare and lodge the objection.
- Engage with the Commissioner throughout.
- Advise on the objection decision and available pathways.
The full scope of our review and audit work
Your audit resolved on the strongest footing, and every stage beyond it covered.
- 01Review and audit strategy.We interrogate the scope of the review or audit and settle with you the strategy for every response, with any later dispute in view.
- 02Information requests and formal notices.We advise on what each request or notice requires and prepare complete and accurate responses within time.
- 03Evidence and records.We examine the records in depth and compile robust evidence to substantiate your position.
- 04Interviews.We prepare you for any interview and attend with you, protecting privileged material throughout.
- 05Technical submissions.We set out the correct technical position and answer the ATO’s reasoning, including in response to any position paper.
- 06ATO engagement.We handle all dealings with the ATO on your behalf, working to narrow or resolve the issues before any assessment issues.
- 07Securing the best resolution.We pursue the best resolution of your audit, whether by persuading the ATO of your position, negotiating a settlement or, where required, taking the matter further through objection.
Our approach
The detail decides the audit.
Information requests, interviews, formal notices and position papers each build the record the ATO relies on. We settle the strategy with you at the outset, interrogate every request and build each response on robust and carefully considered evidence, so your position is put at its strongest from the start.
We pursue resolution at audit wherever it can be achieved. If the matter goes further, the work already done carries straight through to objection and beyond.
We are experienced in tax disputes at every stage, from audit through to the courts. We work with you and your accountant from the first request to the final outcome.
About the firm
A practice dedicated to tax disputes.
Wolfe Kershaw Law is a national tax disputes and litigation practice based in Brisbane. We act for individuals, businesses, private groups and their advisers in disputes with the ATO, from the first request for information through to appeals in the Tribunal and Federal Courts.
We bring an in-depth understanding of how the ATO approaches a dispute at every stage, and experience in matters of every scale, from individuals and family groups to large business and multinationals. That experience shapes how we set strategy, test the ATO’s position and prepare each case.
At audit, that means a record built with care from the first request.
Before you book
Questions about ATO reviews and audits.
01Should I respond to the ATO before getting advice?
It is best to get advice before you respond. What you provide becomes part of the record the ATO relies on, and a formal notice carries legal obligations and time limits. We can advise you promptly so your response is complete, accurate and on time.
02What if I have received a formal notice?
A formal notice can require you to provide information, attend an interview and give evidence, or produce documents, and failing to comply can be an offence. Documents protected by legal professional privilege do not have to be produced. We will advise you on what the notice requires and how best to respond.
03What if the ATO has already issued an assessment?
If the audit has ended in an amended assessment, it may be able to be challenged by objection within the time limit that applies. We review the assessment and the audit record together and advise you on the objection.
04What should I have ready for the initial call?
Please have the ATO’s correspondence, any formal notice or position paper and the dates involved.
Work together
Discuss your review or audit.
Booking a call does not create a solicitor and client relationship. Each booking is reviewed before the call, and we may contact you to reschedule or redirect it if the matter falls outside the practice or raises a conflict.
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