38 min
Trends and updates on ATO challenges to taxpayer LPP claims Think Foley's
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- Education
This presentation provides an update on recent cases and developments regarding taxpayer legal professional privilege claims made against and challenged by the Commissioner of Taxation. Specifically, it addresses:
the Commissioner’s treatment of LPP claims in response to notices issued under s 353-10 of Schedule 1 to the Tax Administration Act 1953 (Cth) by reference to the decision in CUB Australia Holding Pty Ltd v Commissioner of Taxation [2021] FCAFC 171 and the hearings in Commissioner of Taxation v PricewaterhouseCoopers & Ors; the draft ATO LPP protocol released for public comment in late September 2021; and how the Commissioner may use material received pursuant to a notice issued under s 353-10.
This presentation provides an update on recent cases and developments regarding taxpayer legal professional privilege claims made against and challenged by the Commissioner of Taxation. Specifically, it addresses:
the Commissioner’s treatment of LPP claims in response to notices issued under s 353-10 of Schedule 1 to the Tax Administration Act 1953 (Cth) by reference to the decision in CUB Australia Holding Pty Ltd v Commissioner of Taxation [2021] FCAFC 171 and the hearings in Commissioner of Taxation v PricewaterhouseCoopers & Ors; the draft ATO LPP protocol released for public comment in late September 2021; and how the Commissioner may use material received pursuant to a notice issued under s 353-10.
38 min