iscoverThe professional accounting body has backed the Tax Office’s efforts to refresh its approach to providing taxpayer relief concessions following numerous member complaints.
CA ANZ offers feedback on ATO’s draft concessions framework
26 September 2025
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10 minute read
CA ANZ is welcoming the ATO’s move to improve its approach to providing taxpayer relief through taxpayer lodgment and payment deferrals, payment plans, remission of failure to lodge and interest charges.
According to the professional accounting body, there had been numerous member complaints relating to the ATO’s taxpayer relief concessions, which it had shared the key themes of with the ATO.
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In a submission to the ATO, CA ANZ made various suggestions which would aid in achieving the goal of “ensuring that settings were clear, consistent, transparent and aligned to the legislative intent [and desire] to make it easier for taxpayers and their representatives to identify when concessions might be available”.
Based on the number of complaints that had been circulating from CA ANZ members, the body said there needed to be clear guidance and examples of how the ATO managed debts and taxpayer relief provisions, assurance that the provisions were applied consistently and complete explanations for decisions made.
Susan Franks, CA ANZ leader of tax, superannuation and financial services, said: “This type of transparency will provide administrative savings for the ATO, tax agents and taxpayers.”
“CA ANZ receives a substantial number of member complaints about the lack of consistency and transparency about the ATO’s approach to debt collection, and particularly the administration of various methods of taxpayer relief that are the subject of this review,” she said.
“CA ANZ has been consistently advocating for these issues to be reviewed and for practical detailed guidance about how these decisions are made to be publicly available, for several years through various ATO committees, directly with relevant ATO staff and with the Inspector-General of Taxation and Taxation Ombudsman.”
Franks also noted that this review was essential and had high expectations attached to it based on there being over $100 billion of tax debt to collect.
In its submission, CA ANZ responded to the ATO’s five guiding principles of fairness, conditionality, context, engagement and exclusions.
In terms of clarity, Franks said the principles needed to be realised in clear practical guidelines and examples and hoped the internal ATO decision-making documents would be made publicly available along with website guidance which contained common real-life scenarios.
“The conditionality and engagement principles appear to be similar. Consideration may need to be given as to whether they should be combined. In addition, very explicit information is required about ATO expectations regarding when and how a taxpayer should engage with the ATO about these matters,” she said.
“In this context, consideration also needs to be given to the ability of a taxpayer or tax agent to easily make a record of their compliance effort and engagement in the ATO’s systems.”
The impact of the principles was also addressed within the submission, with emphasis that they would have little impact and practical, clear guidelines and dedicated ATO personnel were all that was needed to deal with existing and arising issues.
The fairness principle needed to consider fairness in relation to those who did not pay and were potentially having firmer action taken against them, and taxpayers who could access the small business restructuring provisions, as well as comparing the application of the taxpayer relief provisions to those who paid on time.
“There is a potential danger that by having strict criteria to access the taxpayer relief provisions, those debts will be forced into other areas, which may result in even less tax being collected,” Franks said.
“Consideration should be given to how the principles will apply to firmer action and small business restructuring. These areas also need to have clear public guidelines.”
CA ANZ also recommended the establishment of dedicated areas or teams that dealt with each of the taxpayer relief provisions, and with practical, publicly available guidance on how they operated, would be successful in assisting the ATO in ensuring a consistent approach was adopted efficiently.
This was attributed to the idea that if the ATO expected taxpayers to pay an estimate of their tax before some of the taxpayer concessions applied, then changes were required to the ATO systems, as CA ANZ members had advised that payments of estimated tax had been refunded when they were made without a return having been lodged.
“Tax agents need fast key codes to get to each taxpayer relief area quickly and ideally an automated process within Online Services for Agents.”
“Clear and complete explanations for decisions will improve transparency. Methods to review decisions to deny deferrals/remission also need to be articulated in communication of the result.”
Other feedback provided by the accounting body within the submission was that the context principle needed to include consideration of the degree of control that a taxpayer had over the circumstances, such as increasing globalisation and the difficulty of obtaining information promptly.
Franks said that, based on these suggestions, CA ANZ wanted transparency about the ATO’s approach to administering the various methods of taxpayer relief.
“Ideally, internal ATO guidelines about how these issues are considered and practical common examples of when GIC remission is granted should be publicly available on the ATO’s website.”
“This would enable tax agents to guide their clients, especially small business clients, more efficiently and effectively through this process. Such an approach will provide administrative savings for the ATO, tax agents and taxpayers.”
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