Living with ROSA: implications of the self-assessment changes for tax practitioners

Abstract

Self assessment has been overhauled but how effective are the changes and how will they impact on tax practice? Topics covered in this paper include ATO amendment powers - the basic two-year period and exceptions; changes to the rulings and non-binding advice provisions - the new structure and base provisions; obtaining and relying on private rulings - wider scope, but some dangers; penalties - the new penalty regime; reasonably arguable positions; GIC and SIC; and penalty remission procedures.