How relevant is a reasonably arguable position in dealing with tax risk? This paper includes:
- an overview of the administrative penalties regime
- what is a reasonably arguable position?
- when is it relevant to be in a reasonably arguable position?
- large shortfall amounts/reduction provisions
- taxation statements
- application of taxation law
- taking a position that is reasonably arguable
- what are 'relevant authorities'?
- practical experience and guidance
- alternatives.