ATO Tax Disputes
& Audits
MGS Private represents clients through the full lifecycle of an ATO dispute — from initial review correspondence through to SNC investigations, Behaviours of Concern cases, objections and Federal Court proceedings.
Navigating an ATO
dispute or audit
An ATO audit or dispute is a serious matter — with potentially significant tax, penalty and interest consequences. The way you respond from the first communication matters: admissions made early, documents produced carelessly, and positions taken without legal analysis can all compromise the ultimate outcome.
Initial Review Correspondence
Responding to an ATO request for information or documents — structuring the response to protect privilege, limit disclosure and present the client’s position clearly.
Audit Interview Preparation
Preparing the client and representatives for ATO interviews — ensuring the factual record is established correctly and the legal position is protected throughout.
SNC & Behaviours of Concern
The ATO’s Serious Non-Compliance and Behaviours of Concern programs involve the most intensive audit activity. MGS Private has experience representing clients through these investigations — including complex trust structures and multi-year audits with significant penalty exposure.
Position Paper Responses
Responding to ATO position papers — which set out the ATO’s proposed findings before a formal assessment is issued — with substantive legal submissions and factual analysis.
Penalty Mitigation
Where penalties are imposed, advising on grounds for remission — reasonable care, reliance on professional advice, and full cooperation with the ATO during the audit.
Voluntary Disclosures
Advising on voluntary disclosure to the ATO — where self-correction can reduce penalty exposure and interest accumulation before the ATO identifies the issue independently.
Facing an ATO audit or dispute?
Early engagement matters significantly. Brief MGS Private through your accountant or lawyer.