Managing Disputes (ATO)
Expert leadership and peace of mind during complex ATO reviews, audits, objections, and Director Penalty Notices (DPNs).
Facing a dispute with the Australian Taxation Office or State Revenue authorities can be daunting and disruptive to your business. The stakes are high—financially, operationally, and reputationally. But tax authorities don’t always get it right. You have options, and you have rights. We lead and manage complex disputes with the ATO on your behalf. We coordinate strategy, evidence, and submissions, working toward pragmatic resolutions while protecting your legal and financial position.
Without expert representation, you risk accepting unfavorable outcomes or facing escalating penalties and interest charges.
Precise, Practical
& Proactive.
Our Core Offerings
Comprehensive Dispute Resolution Support
We offer end-to-end support across the full lifecycle of tax disputes, guiding clients from early engagement with the ATO through to formal resolution if required. Our approach focuses on reducing risk, managing exposure, and achieving practical, commercially sensible outcomes while safeguarding your position at every stage.
Tax Audits & Risk Reviews
We represent clients throughout ATO audits, reviews, and investigative programs, ensuring clear communication, strong technical responses, and strategic management of information requests. Our goal is to control the process, defend your position, and resolve issues efficiently before they escalate further.
Objections
When an assessment or decision is incorrect, we prepare and lodge detailed objections supported by robust technical arguments and evidence. We aim to demonstrate the proper tax outcome clearly and persuasively, improving the likelihood of reversal without the need for litigation.
Tax Debt Recovery Defense
We assist in challenging disputed tax debts, defending against ATO recovery actions, negotiating payment arrangements, and responding to director penalty notices. Our focus is on protecting your rights, managing cashflow pressures, and achieving fair and sustainable resolutions.
Early Engagement
Proactive engagement with the ATO can often prevent disputes from escalating. We help open lines of communication early, clarify issues before they become contentious, and maintain a constructive relationship with revenue authorities during sensitive or complex matters.
Alternative Dispute Resolution
We facilitate negotiated outcomes through ADR processes such as mediation, settlement discussions, and ATO-led facilitation. This approach aims to resolve disputes more quickly and cost-effectively while reducing disruption to your business operations.
Voluntary Disclosures
When past errors or omissions need correcting, we guide clients through voluntary disclosures to minimise penalties and secure favourable terms. Our strategic approach ensures transparency while protecting your position and achieving the best possible outcome.
Private Rulings
We obtain clarity and certainty by preparing private ruling applications that clearly outline the relevant facts and technical basis for your position. Whether for a single issue or a broader class ruling, this process provides confidence in the tax treatment of key transactions.
Reasonably Arguable Position Papers
We develop detailed technical papers that support your tax positions and provide penalty protection under Australia’s safe harbour provisions. These documents strengthen your compliance framework and demonstrate a well-reasoned basis for your approach.
Administrative Appeals Tribunal (AAT)
When disputes progress to the tribunal stage, we provide full representation, including evidence preparation, technical argumentation, and negotiation throughout the process. Our objective is to secure the most favourable outcome while minimising uncertainty and business disruption.
This service is for anyone facing ATO scrutiny who needs clarity, protection, and expert representation.
Tax disputes can affect businesses and individuals when the ATO challenges your tax position, issues unexpected assessments, or questions your reporting.
How Disputes Commonly Arise
• ATO audits or reviews questioning your tax treatment
• Amended assessments increasing tax liabilities
• Denied refunds, credits, or entitlements
• Penalties or interest for alleged non-compliance
• GST, residency, or income-characterisation disagreements
• Transfer pricing or cross-border tax adjustments
Why Expert Support Matters
• Clear explanation of your legal position and options
• Strong technical defence backed by tax law expertise
• Guidance through complex ATO procedures
• Skilled negotiation with revenue authorities
• Strategic escalation when required
ATO Dispute Timeline (At a Glance)
-
Risk Review Stage- ATO flags concern via letter.
- Data matching triggers review.
- 3-6 Months. -
ATO Audit Begins-Detailed review of tax years and issues.
- Postion Paper may be issued.
- 1-2 years. -
Notice of Ammended Assessment- Tax, interest & penalties calculated.
- Burden shifts to taxpayer to prove ATO wrong.
- 2-4 weeks after audit. -
Lodge Formal Objection- Fresh ATO office reviews
- Must fully address ATO's reasoning
- Lodge within 60 days; ATO may take 2-4 months. -
ATO Debt Recovery Actions- ATO can pursure debt even if objection underway.
- Includes garnishee notices, DPNs, freezing orders -
Review by ART or Federal Court- Formal legal process to dispute objection outcome
- 6-12 months (ART); 1-2 years (Federal Court) -
ATO Debt Recover Appeal to Full Federal or High Court Actions- Only on points of law.
- Very costly and complex.
- 6-12 Months.
Our Process
Defined Scope
&
Timelines
Know what's covered and when to expect results.
Flexible Pricing
Options
Choose between fixed-fee or retainer as per need.
Expert Senior
Review
Senior deliverable review for accuracy and insight.
Proactive
Guidance
Future-forward guidance, strategy and advice.
Don't Face the ATO Alone – Your rights. Your interests. Expertly defended.
Tax disputes can be stressful, time-consuming, and costly. But with the right advisors, you can assert your rights, defend your position, and achieve resolution with confidence. Whether you're facing an audit, challenging an assessment, or preparing for tribunal proceedings, Saby+ Partners has the expertise and experience to guide you through. Contact us today for a confidential discussion about your tax dispute and how we can help you achieve the best possible outcome.