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The approach to administration of the Australian tax system has, over time, fluctuated between an adversarial and a co-operative approach. Currently, consistent with a move to a responsive regulatory strategy, the Australian Tax Office (“ATO”) has expressed its desire for a co-operative partnership style relationship with the tax advising profession. The profession is seen, in its view, as a critical leverage point to promote voluntary compliance with the tax system by the bulk of taxpayers.The advent of a partnership style relationship between the ATO and the tax profession raises many issues, primary of which is whether the desire to establish this relationship is mere rhetoric employed by both parties in the pursuit of their divergent interests. In fact, the very existence of these opposing interests raises the possibility of ethical conflicts that need to be carefully managed by both parties to the partnership.

Partners or Combatants: A Comment on the Australian Tax Office's View of its Relationship with the Tax Advising Profession