The ATO or SRO may issue a notice of assessment or amended assessment following an audit or data-matching exercise.
If you dispute the assessment, there are strict timeframes within which you can lodge an objection. It is important to strategise the arguments you rely upon at this stage, as this can influence your options for resolution in later stages if the dispute progresses.
Aptum’s tax disputes leaders worked at the ATO for over a decade and have experience dealing with the SRO. We understand how revenue authorities approach evidence and make decisions.
Aptum can help position you towards a clear, well-structured objection that focuses on the key issues and puts you on the front foot with the ATO or SRO. We can do so on your behalf or work with your preferred accountant or tax agent.
How can Aptum help?
- reviewing audit decisions, such as disallowing claims for research & development (R&D) expenditure and GST;
- preparing and lodging an objection on your behalf that presents the tax law and evidence in the strongest possible way to support your position;
- advising you on specific pathways that are available to you, to position you for the best possible outcome; and
- engaging directly with the ATO or SRO with engagement products that are only available at this stage.
"The result Aptum achieved for me was exceptional. I have no criticisms. I hope not to require Aptum's services again, but if I do, I would, without question, instruct them."
– Anonymous (sourced from the 2024 Client Choice Awards)
What makes Aptum different
Legal intelligence framework
Practical, ongoing risk assessment to focus on the essential.
Project management framework
Routine documented strategy through custom project management.
Case study
When it didn’t work with a tax agent, Aptum helps an individual get the ATO to reconsider a AUD$1.5M deduction
Problem: The trustee of a family trust was disallowed a substantial deduction (more than AUD$1.5M) on a lost investment. The trustee had initially failed in the objection process with representation from their tax agent. The trustee then made an application in the ART to argue that the absence of the trust resolution meant that their assessment should be reconsidered.
Aptum’s role: Aptum was engaged because the application was failing. Aptum filed a further application that the ATO could still consider the trust resolution grants, and due to resource constraints, did so without briefing counsel. This review application raised novel and complex questions regarding trust law and assessment of trust income. Aptum was responsible for conceiving of and advocating the arguments before the Tribunal.
Outcome: The ATO subsequently entirely dropped its opposition to the application (after several years of resistance) and consented to the assessments being set aside in full.
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ATO Objections FAQs
Michael Buscema, Aptum’s practice lead for tax disputes, answers some of the most frequently asked questions about ATO objections and tax disputes with the ATO.
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