This paper looks at these matters from an external perspective including:
- does the company/board have a tax risk charter and what are its advantages?
- what processes have you established to deal with assessing tax risk on transactions?
- how do you brief management/board on tax risk without creating or elevating the risk in doing this?
- the ATO Board papers privilege and the limitations of this
- recent developments in LPP (including the Rio decision)
- how do you determine the appropriate strategy for dealing with the ATO
- controlling the interaction of the ATO with the organisation so that there are "no surprises"
- managing information flows and responses during an ATO investigation stage.