Tax dispute resolution and controversy in life sciences

Tax dispute resolution in life sciences

Does your organisation have a review and audit readiness strategy?


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As patient treatment becomes more personalised, access to quality treatment data and information will be one of the key drivers of success in the life sciences sector. Similarly, access to adequate documentary and oral evidence which supports your organisation’s tax positions is key to a successful outcome in an Australian Tax Office (ATO) review, audit or dispute.

We’ve seen a heightened focus by the ATO on the life sciences sector, particularly pharmaceutical and medical devices, along with a surge in the number of information gathering notices issued in recent years and increased use by the ATO of its information access powers. Your organisation’s ability to respond with objective facts, evidence and sound technical arguments, along with proactive management of engagement with the ATO throughout the process, is fundamental to your review and audit readiness strategy.

Questions to consider

  • How confident are you about our organisation’s readiness to proactively manage engagement with the ATO in event of a review, audit or dispute?
  • Do you have access to sufficient documented and/or oral evidence throughout the period under review or audit?
  • Are you able to provide compelling facts and objective evidence to support positions taken?
  • Has evidence been collected and documented on a timely basis? 
  • Are relevant witnesses available and willing to assist?
  • Have you obtained relevant tax technical advice and do you have a reasonably arguable position?
  • Are you in a position to respond within tight deadlines to requests for information, keeping in mind that extensions are rare in the case of certain notices?

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