Revenue Law

Although tax authorities are increasingly moving to digitalisation, there has been limited use of blockchain for assisting tax administration and compliance. This article discusses the potential use of blockchain technology for this purpose. In particular, the Australian tax system is considered in light of the challenges identified in the recent official report published by the House of Representatives Standing Committee on Tax and Revenue. These challenges result from the rising gig economy, complex work-related deduction rules for individual taxpayers and, more generally, tax evasion in the cash economy. To overcome these challenges, this article proposes a blockchain solution that increase taxpayer engagement with the tax and superannuation system. Not only would this solution benefit the Australian Government's ability to raise revenue and induce a good compliance culture, but a similar solution could be adopted in other jurisdictions.

The depreciation rules for tangible assets in Australia's income tax law have evolved in two distinct phases. From 1915 to 1992, legislative amendments sought to overcome the limitations of a rigid and limited depreciation system through gradual expansion of the depreciation regime to more and more types of tangible assets and at the same time develop the depreciation rules into a tool for economic intervention. A partial consolidation of the rules in 1992 marked the beginning of a shift in depreciation policy to become a tool in a broader neoliberal agenda. This article explores the evolution of the depreciation rules for tangible assets in the initial seven and a half decades. The history of depreciation rules in this period provides useful insights into the view of Australian governments on both sides of the political divided of tax law as a tool to achieve economic policy objectives.

This is a critical comment on a review of the research methodology in tax compliance costs by Turner, Smith and Gurd in the Revenue Law Journal” volume 8, 1998. It argues that there are inaccurate assertions in their review. Many of their recommendations, while correct, are well known in the literature and difficult to implement in practice. In evaluating previous Australian studies, Turner, Smith and Gurd did not take account of resource constraints facing early researchers. They failed also to highlight in a systematic fashion the conceptual advancement and improvements in data collection in the more recent studies.

This is a critical comment on a review of the research methodology in tax compliance costs by Turner, Smith and Gurd in the Revenue Law Journal” volume 8, 1998. It argues that there are inaccurate assertions in their review. Many of their recommendations, while correct, are well known in the literature and difficult to implement in practice. In evaluating previous Australian studies, Turner, Smith and Gurd did not take account of resource constraints facing early researchers. They failed also to highlight in a systematic fashion the conceptual advancement and improvements in data collection in the more recent studies.

The views expressed in this chapter are those of the authors and do not necessarily reflect the views of Atax, University of New South Wales, or the Fraser Institute. Information provided by Nick Botfield, Director of Pre-filling of Tax Returns, Australian Taxation Office (ATO), is gratefully acknowledged, as are the comments of an anonymous referee of this chapter.

The Legal and Social Issues Committee of the Victorian parliament will soon publish a report on spent convictions and criminal record discrimination. Victoria is the only state in Australia that does not have a spent convictions scheme. The purpose of this article is to review the recent decision of the High Court in Frugtniet v ASIC, a decision about the federal spent convictions scheme, and outline the lessons that decision provides for Victoria and for the successful appellant in that case.

The New Zealand Government proposed in August 2004 a 'radically' new approach to address evasion in industries which is perceived to be ingrained, namely targeted amnesties. With a general election and other 'more pressing' issues, the proposal has not been significantly advanced. This paper provides further guidance for implementing a modified targeted amnesty concept, including a proposal from the author to consider incorporating targeted amnesties within the existing Industry Partnerships program that the IRD has been developing since late 2001. Although the Government's proposal addresses concerns with evasion that is ingrained in some industry groups it makes no direct links between the targeted amnesties proposal with the IRD's Industry Partnership program. Clearly, to raise expectations that amnesties would only be targeted to industry partners would run counter to one of the core concepts for tax administration in New Zealand-the protection of the integrity of the tax system including taxpayer perceptions of that integrity.

Journal of the Australasian Tax Teachers Association (JATTA) is a double blind peer review refereed journal. It is normally published annually and subsequent to the Association's annual conference. The Australasian Tax Teachers Association (ATTA) is a non-profit organisation established in 1987 with the goal of improving the standard of tax teaching in educational institutions across Australasia.

The 1998 Federal budget included an allocation of $1.74 million over four years (1998/99 to 2002/2003) for “[d]eveloping more and better Clinical Legal Education to maximise service delivery to disadvantaged clients and cooperation with universities”. This is a significant development for Australia’s small clinical legal education (CLE) movement which, with only one exception, had not previously received direct Federal funding. While this provision of funding is obviously welcomed, the Commonwealth government’s objectives for this funding appear to focus on community service rather than educational outcomes. The Commonwealth is clearly of the view that CLE has potential as a vehicle for the provision of inexpensive legal advice.

This book examines current issues of constitutional law in Australia from the perspective of a group of Commonwealth and State Solicitors-General and academic lawyers. The topics covered include : the nature of appropriation (including the Commonwealth spending power); excise duty; section 92; Commonwealth prerogative powers; industrial powers; and the Imperial connection. ACKNOWLEDCMENT S The Centre for Research on Federal Financial Relations records its appreciation to ANU Graphic Design for designing the cover of this Monograph , to Ma P.A. de Lacy for typing the manuscript, to Mrs A. M. Wllldnaon for her editorial work and for malting the necessary publication arrangement a.

This paper argues that there is a fundamental concept implicit in the interpretation of the Australian Constitution which postulates that that document should be approached from the perspective of what I have called for convenience "One Australia". It is a concept which suggests that the Australian courts should, where appropriate, take into account that Australia is one nation and one people operating under a "unitary" system of Australian domestic laws. It arises from the evolution of Australian nationhood and from the increasingly interdependent nature of Australian society. It is suggested that this concept is already exerting an influence on judicial decision-making in this country, to be balanced with other constitutional fundamentals, including that of the federal system. However it is also asserted that the full implications of "One Australia" have not as yet been determined. This is particularly so in relation to Commonwealth territories and their residents. The latter have in the past been generally regarded as being of little importance, both constitutionally and otherwise. Recent developments in some of these Territories, and their growing importance within the Australian nation, directly raise the question of the applicability of the concept of "One Australia" to them, particularly as it might be held to impinge on the constitutional place of such territories in Australia and on the constitutional rights of their residents. At present it can be said that there are two classes of Australians in constitutional terms, those in the territories and those in the States, with those in the former having an inferior position in this regard. The question raised is whether Australian courts will seek to address this constitutional form of disadvantage, in so far as it is within their capacity to do so, by having regard to the premise of "One Australia". That there could be such an implication is not a novel concept. It is well established that there are certain fundamental concepts or principles inherent in or implied into the Australian Constitution which are not, or not fully, expressed in the written text. The concepts of responsible government, 1 and representative democracy,2 are good 1

The traditional view as regards general consumption taxes is that excluding certain products from the base decreases their natural regressivity. Whilst this view has been consistently questioned over the last forty years, public perceptions are still heavily influenced by it. Drawing insights from the legislative history of the old European VAT system and the newer Australian VAT system, this paper demonstrates how policy debates and changes in VAT rates have been heavily influenced by those public perceptions; and how special interest groups, which would be set to lose out from broad base VATs, are able to use the information asymmetry behind those perceptions to defend their interest in favour of base narrowing, or against base broadening reforms. The paper presents a novel analytical and conceptual frameworkinformed by tax law, political economy, political science, behavioural science, and regulatory theoryof the likely factors behind the prevalence of those public perceptions. It demonstrates how, in the absence of external pressures, they result in increased use of reduced rates over time, and the consequent narrowing of the tax base. It concludes by presenting a new pathway to shift public perceptions, and to overcome the political resistance to broad based consumption taxes. I. Introduction General consumption taxes, like VAT, are commonly regarded as regressive. 1 The traditional response to concerns over this regressivity has been the exclusion of certain products from full taxation, on the presumption that this exclusion will achieve social and distributional aims. The argument is twofold: first, non-taxation will increase consumption of products with positive externalities, so-called merit goods, such as cultural events, sport events and books; and, second, non-full taxation of essential products, such as food, healthcare and education, will diminish the natural regressivity of consumption taxes. Non-full taxation is achieved primarily through either exemptions or reduced rates, and both methods are widely used within Europe, as well as in many other countries applying a VAT, including

Judicial review of the decision of the Australian Taxation Office (' ATO') to lift the Accountant's Concession has proved a fruitless and expensive exercise for taxpayers. The Accountant's Concession lays down administrative arrangements restricting access to papers prepared by professional accounting advisers. While it has been suggested reliance on 'exceptional circumstances' to lift the concession best serves capital and tax markets, elsewhere it has been argued that the concession must be rethought if the policy of enabling full and frank disclosure is to be achieved. This article examines initiatives aimed at shielding tax advice of accountants from the Tax Commissioner's coercive access powers under the Income Tax Assessment Act 1936 (the ' Act') and elevating the current administrative arrangement into the statute. This would make the limited procedural legitimate expectation a substantive procedural right. This would remove the different treatment of lawyers and accountants offering tax advice and eradicate the delays and uncertainty associated with the separate tax advice privilege recommended by the Australian Law Reform Commission.

This is a critical comment on a review of the research methodology in tax compliance costs by Turner, Smith and Gurd in the Revenue Law Journal” volume 8, 1998. It argues that there are inaccurate assertions in their review. Many of their recommendations, while correct, are well known in the literature and difficult to implement in practice. In evaluating previous Australian studies, Turner, Smith and Gurd did not take account of resource constraints facing early researchers. They failed also to highlight in a systematic fashion the conceptual advancement and improvements in data collection in the more recent studies.

Grammatical, purposive, contextual, teleological and comparative interpretations are the most commonly used modalities for construing statutory texts. In Australia, interpretation of tax laws involves a combination of taking account of the law-text, its context, and its underlying purpose or policy. Ultimately, the meaning ascribed must be that which best reflects and gives effect to the legislature's intention as emerging from the statute. A value-based (teleological) interpretive approach does not, as yet, have a strong foothold in Australian jurisprudence, except to a limited extent under, for example, s 30 of the Human Rights Act 2004 (ACT) and s 32(1) of the Charter of Human Rights and Responsibilities Act 2006 (Vic). In South Africa, on the other hand, the basic approach to interpreting tax legislation is that its words are to be construed by reading and understanding the whole text in the light of its broader context. A meaning assigned must be appropriate and consistent within the limits of (i) the language of the text, (ii) the context and purpose of the text, (iii) the overall objectives of the legislation, and (iv) the relevant values and/or fundamental rights arising from the Constitution of the Republic of South Africa 1996 ('the SA Constitution'). As a result of the SA Constitution's supremacy and the provisions of s 39(2) therein, the meaning ascribed to a law-text must be that which, all legally relevant things considered, best promotes the spirit, purport and objects of the Bill of Rights.

The tax compliance behavioural literature indicates that, among other factors, demographic variables play an important role in the compliance behaviour of taxpayers. This exploratory study investigated the relationship between demographic variables and Australian personal taxpayers’ attitudes towards tax evasion. An electronic survey of 300 Australian personal taxpayers’ was conducted by a market research company on behalf of the author. The findings revealed that, for the majority of the demographic variables analysed, statistically significant relationships were established with Australian’s attitudes towards tax evasion. These results provide useful information for revenue collecting authorities and have implications for tax policy development.

The issue of tax compliance costs continues to attract public attention throughout the OECD. This is particularly true in Australia, where major tax reforms are taking place. This paper reports on an ongoing research project on federal tax compliance costs conducted by a research team from the Australian Taxation Studies Program (ATAX) of the University of New South Wales. The focus of this paper is on the methodology of estimating taxation compliance costs. Some aggregate empirical findings, based on several large-scale mail surveys of over 10,000 personal and business taxpayers, will be reported. Major differences between the Australian and U.S. tax systems, as well as comparison with results obtained in previous UK and U.S. studies, will also be highlighted.

The courts were only recently given their first opportunity to consider the substantive operation of Part IVA of the Income Tax Assessment Act 1936 (Cth) in the trilogy of Peabody v FCT. Given the potential scope of Part IVA, an understanding of the Courts’ appraisal of the legislation’s breadth is crucial for all taxation practioners. Whilst aspects of the High Court’s judgment particularly its view as to the Commissioner’s discretion under s 177F, may cause taxpayers concern, other aspects of the judgment affirm the existence of significant limits upon Part IVA’s scope. When coupled with Hill J’s acceptance that transactions entered into for commercial reasons are not caught by Part IVA, it is submitted that Peabody provides an appropriate balance between preventing tax avoidance and not discouraging business and family transactions.

This article attempts to unravel the complexities of the High Court’s recent pronouncements on the scope of the capital gains provisions in Hepples v FC of T. While four members of the Court believed the subject receipts taxable, the Court nevertheless held in the taxpayer’s favour.

Extract]Tax avoidance has been a problem for governments since taxes were introduced. Thirteenth century English property taxes were avoided by taxpayers moving their assets outside the sheriff 's jurisdiction. Even more conniving were the citizens of 17th century England who avoided the Window Tax by covering their windows before the tax collector's visit.

The Australasian Tax Teachers Association (ATTA) is a not‐for‐profit association originally aimed at improving the standard of tax teaching in institutions of higher education in Australia and New Zealand. It was established as an informal network of tax academics in 1987 although the first formal conference did not take place until 1989. ATTA members organise annual conferences which are hosted by a different institution each year. The members agreed early on that in principle every fourth conference should take place in New Zealand, although this has not always been achievable often due to budgetary constraints and also other practical reasons. Furthermore, it is often the larger universities that have hosted the conference, also for budgetary and practical reasons. At the 2013 conference which was held at the University of Auckland it was decided that it was time to draft a new constitution and also investigate formalising the organisation of ATTA as an incorporated association. ...

Islamic banking and finance is emerging in global financial markets and governments seek to facilitate it. This article focuses on whether it is constitutionally possible for Australia to implement reforms to facilitate faith-based financial transactions. There have been calls for Australia to become a financial hub – particularly in South East Asia. One aspect of this is the recognition of Islamic finance as an alternative in the marketplace. This would include ensuring that tax laws are synchronised with Islamic tenets on financial transactions and do not hinder such alternatives. Being different to conventional finance, Islamic finance has attracted interest and scepticism, partially because of the lack of understanding and the paucity of academic research on the subject. While the idea of facilitating faith-based finance may seem economically rational, a fundamental question needs to be addressed: is it appropriate for Australia’s tax laws to be amended to facilitate what may be...

Islamic banking and finance is emerging in global financial markets and governments seek to facilitate it. This article focuses on whether it is constitutionally possible for Australia to implement reforms to facilitate faith-based financial transactions. There have been calls for Australia to become a financial hub – particularly in South East Asia. One aspect of this is the recognition of Islamic finance as an alternative in the marketplace. This would include ensuring that tax laws are synchronised with Islamic tenets on financial transactions and do not hinder such alternatives. Being different to conventional finance, Islamic finance has attracted interest and scepticism, partially because of the lack of understanding and the paucity of academic research on the subject. While the idea of facilitating faith-based finance may seem economically rational, a fundamental question needs to be addressed: is it appropriate for Australia’s tax laws to be amended to facilitate what may be...

SINDH LAND REVENUE LAW Q1: Discuss the various classes of revenue officers and their duties. Introduction: Under land revenue act 1967 there are various classes of revenue officers. The act describes appointment power duties and functions of revenue officers. Administrative control in revenue matters all over a province is exercised by the board of revenue; even revenue officer is subject to control and supervision of the officer to whom he is subordinate. Definition of revenue officer: According to sec. 4 (23) of the revenue act: "Revenue officers mean a revenue officer having authority under this act discharge the functions of a revenue officer." Classes of revenue officers Following are various classes of revenue under land revenue act 1967. (I) Board of revenue (ii) Commissioner (iii) Collector (IV) Assistant collector of 1st grade (v) Assistant collector of second grade Board of revenue: The board of revenue is the highest authority revenue matters. Definition: "Board of revenue means the board of revenue established under the Sindh Board of Revenue Act 1957." Duties:  The board of revenue exercise general superintendence and control over all revenue officers.  The board of revenue appoints and transfers the revenue officers.  The board of revenue is the highest court of appeal and revision.  The board of revenue distributes business and withdrawal and transfer cases. Commissioner: The province is divided into division. The Commissioner is an incharge of a division and all officers are subject to its control. The Commissioner shall be appointed under the land revenue act for each division. Duties  The Commissioner can distribute any business to any officers under its control.  The Commissioner can transfer any case pending before any subordinate officer to any other officer subordinate to him.  The Commissioner may withdraw any case pending before any subordinate and shall either to dispose of it himself or to transfer to any other offices subordinate to him to be disposed of.  The Commissioner may refer any case which he is empowered to dispose of under this act any other revenue subordinate of investigation and report and may decide the case upon such report after giving the parties concerned an opportunity of being heard.  Commissioner can summon any person whose attendance he considers necessary for the purpose of any business before him as revenue officers. COLLECTOR/DISTRICT COMMISSIONER: The Collector is the head of a district. He is district officer revenue in a district. The collector is the most reasonable position holder of a district and perform multi-task duties. The collector shall be appointed under land revenue act 1967 in a district.

This article discusses the effect of the capital gains tax legislation on a resident Australian taxpayer who ceases to be a resident of Australia for taxation purposes. It is the object of this paper to review whether the capital gains tax legislation as it relates to non-residents provides scope for tax planning and/or avoidance.

Maimonides, known as the Rambam, was one of the greatest arbiters of all times on matters of Jewish law, one of the greatest philosophers of the Middle Ages, a scientist and researcher, a court physician, and a pre-eminent leader in the society of his time. In addition to his monumental work on Jewish law and ethics, his writings on medicine are classic and remarkable even in the present day. Rambam Health Care Campus in Haifa, Israel, which bears with pride the name of Maimonides, the Rambam, and aspires always to act by his guiding principles, is pleased to announce the launching of a new open-access journal, the Rambam Maimonides Medical Journal. This peer-reviewed publication will be sponsored by Rambam Health Care Campus and authored by leading physicians and scientists worldwide. RMMJ will focus on clinically relevant biomedical research and additional issues central to the provision of optimal health care to patients, disease prevention, and public health, and will provide an address for original articles about translational clinical and basic research that moves discoveries from the bench to the bedside and from the bedside to the community. The journal will also publish reviews, "Rambam Grand Rounds", and symposia reports as well as special essays concerning ethical and societal aspects of medicine.

This note suggests that unless the Full Federal Court decision in FCT v Macoun [2014] FCAFC 92 is overturned by the High Court in the upcoming appeal, the literalist interpretation of domestic legislation enacting international obligations preferred by the Federal Court would set a dangerous and unwise precedent that is not only antithetical to the consistent and uniform development of international law in Australia but also to Australia’s effective participation in the OECD/G20 Base Erosion and Profit Shifting Project.

Green taxes are used widely overseas and increasingly in Australia. There are four main categories. 1. Taxes, levies, fees and other charges, including development taxes, rezoning charges, emission charges, emission licence fees, environmental protection charges, input taxes, resource rents and royalties, sliding charges for utilities, and product levies. 2. Tradeable, bankable and marketable rights and credits, including tradeable emission rights, emission reduction credits, transferable development credits, tradeable resource quotas, and tradeable emission leases. 3. Other economic instruments such as refundable deposits, performance bonds and guarantess, and subsidies, 4. Income tax concessions and differential sales taxes and import duties. Recent High Court authority suggests that whilst some of these instrucments would be excises and hence could be imposed only by the Commonwealth, most could also be imposed by state government and some also by local government. Their economic...

No government can be sustained without the ability to tax its citizens. Democratic societies typically guarantee, in varying forms and degrees, a basic set of taxpayer rights. These rights are essential in establishing an effective and reasonable taxation process.Author Duncan Bentley's work argues that it is timely and beneficial to articulate a Model of taxpayers' rights as a guide to best practice in tax administration. It first finds a rationale for a Model in legal and rights theory and concludes that a Model is necessary, timely and a realistic option in the context of current developments in tax administration. Next, it articulates the principles that should underlie any Model. These are drawn from traditional analysis of tax systems and refined to provide a standard approach and interpretation. It is noted that the content of any Model will be determined in part by the approach taken to its interpretation.A classification of taxpayers' rights in the context of th...

The Henry Report on the future of the Australian tax system examined many areas of rel-evance to tax systems in general. One was the tax treatment of employment expenses. The Henry Report recommended that a new test should be introduced to narrow the definition of deductible employment expenses and that this test might be similar to the approach taken in the UK. In the light of the basic principles of the issue, this paper examines the reasons for the recommendation and the extensive experience of the UK arrangements. The situation in New Zealand is also examined as another approach. Finally a possible solu-tion is suggested. Key words: Henry Report, Taxation, Work related expenses

Electronic commerce is one of the fastest growing industries in the global economy including in the developing and least developed countries. The advancement in information and communication technologies and the internet has offered the brick-and-mortar businesses additional marketing channels to transact online. The prospects that came with electronic commerce, however, are not without drawbacks. One of the challenges is related to the power of developing economies to levy and collect taxes on such online businesses. This paper seeks to examine the prospects and potential challenges in the taxation of electronic commerce from a legal perspective. It examines the existence or otherwise of an enabling legal and regulatory environment for the taxation of electronic commerce in Ethiopia. In so doing, it employs a qualitative doctrinal research methodology and heavily relies on binding domestic and international legal and policy frameworks as primary sources of data and pertinent literatures as secondary sources. It introduces some possible approaches of addressing potential challenges.

This material was first published by Sweet & Maxwell Limited in Angelo Nikolakakis, Stephane Austry, John Avery Jones, Philip Baker, Peter Blessing, Robert Danon, Shefali Goradia, Johann Hattingh, Koichi Inoue, Juergen Luedicke, Guglielmo Maisto, Toshio Miyatake, Kees van Raad, Richard Vann and Bertil Wiman, “Some Reflections on the Proposed Revisions to the OECD Model and Commentaries, and on the Multilateral Instrument, With Respect to Fiscally Transparent Entities”, British Tax Review, Vol. 2017, No. 3, pp. 295-373, 2017 and is reproduced by agreement with the Publishers. This article sets out some reflections of the authors on those aspects of the OECD’s October 2015 final report on Neutralising the Effects of Hybrid Mismatch Arrangements (the Hybrids Report) that relate to revisions to the OECD Model to add a specific provision on fiscally transparent entities (as a new Article 1(2)), and to build on the Commentaries already in place in this regard (the HR Proposals). It also c...

This study aims to analyze the level of urbanization, education, and income towards g ross d omestic p roduct in Banda Aceh. The variables used in this study are urbanization variables, education variables and , g ross d omestic p roduct variables in Banda Aceh. This study uses panel data in the period 2015-2018 , and the analysis model used is a qualitative method. The results showed that the GDP and Education variables had a positive effect on immigration in Aceh. Urbanization variables showed positive results on labor growth. Labor variables show positive results on GDP growth. This study shows that all of these variables show positive results. The results of this study are expected to be one of the indicators of the government to choose policies implemented in Aceh's economy. Keywords : Urbanization, education, income, Gross Domestic Product

This article examines the interpretation and application of the continuity of business tests (generally known as the "same business test") for the carry forward of losses and the deduction of bad debts. It provides a critique of the Australian Taxation Office (ATO) analysis of the old provisions. It then makes suggestions on how to approach the new provisions which have been rewritten by the Tax Law Improvement Project.

Most tax books are kept for reference. This is the first of two volumes that any person involved in any aspect of taxation should read. These books represent the synthesis of current thought on how to design tax systems. What relevance is that to average tax practitioners? It enables them to understand their own tax system and why it operates as it does. This volume deals with the .legislative process, legislative framework, drafting, and administrative design of tax law, and the design of systems of mainly indirect taxation. The second volume deals with design of taxes on direct taxation and investment. Unfortunately, only five of the 23 chapters deal with legislation and tax administration. Experience suggests that they are just as crucial to the successful operation of a tax system as the taxes themselves.

2 Different law schools have different names for a unit of study, including topic, subject and course. We will use the term 'course', meaning a unit of study that counts towards a student's program completion. Our course is 'elective' in the sense that it does not comprise one of the 17 compulsory courses within the JD program at MLS. Within our program, international law is not a required or compulsory course.

The current tax disputes resolution procedure, introduced in New Zealand (NZ) with effect from 1 October 1996, includes an extensive pre-assessment phase-the aim of which is to resolve tax disputes without the need for litigation. While this objective of the regime arguably has been achieved it has come at a price for taxpayers; in particular the costs of the new process are such that some tax disputes are not worth pursuing with taxpayers preferring to concede their dispute with Inland Revenue. In response to concerns raised by commentators and professional organisations about the operation of the disputes resolution process, in 2010 Inland Revenue released an Issues Paper for consultation. This included a cursory and, in the author's view, dismissive review of the approaches in Australia, Canada and the United Kingdom to dealing with small tax disputes. This article reviews the small tax dispute resolution processes adopted in these countries and concludes a separate forum or ...

In his 2011 comparative study, Maples 3 observes that, despite the then recent positive administrative changes implemented by Inland Revenue (including facilitated conferences and the ability to opt-out of the dispute process after the conference phase), "these changes do not alter the fact that the [New Zealand] dispute process essentially provides 'a one size fits all' procedure for tax disputes, irrespective of their complexity and the amount in dispute." Moreover,

The New Zealand Government proposed in August 2004 a 'radically' new approach to address evasion in industries which is perceived to be ingrained, namely targeted amnesties. With a general election and other 'more pressing' issues, the proposal has not been significantly advanced. This paper provides further guidance for implementing a modified targeted amnesty concept, including a proposal from the author to consider incorporating targeted amnesties within the existing Industry Partnerships program that the IRD has been developing since late 2001. Although the Government's proposal addresses concerns with evasion that is ingrained in some industry groups it makes no direct links between the targeted amnesties proposal with the IRD's Industry Partnership program. Clearly, to raise expectations that amnesties would only be targeted to industry partners would run counter to one of the core concepts for tax administration in New Zealand-the protection of the integrity of the tax system including taxpayer perceptions of that integrity.