Since 2015 the IGTO has performed two separate, but complementary, roles: the Inspector‑General of Taxation and the Taxation Ombudsman. These distinct roles are both investigatory in nature and serve to improve the administration of the Commonwealth's taxation laws and systems.
The Inspector‑General function provides assurance to the public, the tax profession, and the government on the operation of the Commonwealth's taxation laws, as well as the administration of those laws by the Australian Taxation Office (the ATO) and the Tax Practitioners Board.
The Taxation Ombudsman function performs a distinct, yet complementary, role within the taxation system, and provides a personalised service for taxpayers and their representatives. The IGTO sees this function as helping people make sense of their direct experience with the tax system, and to ensure fairness and transparency in their dealings with the ATO and the Tax Practitioners Board.
These functions are undertaken pursuant to section 7 of the Inspector‑General of Taxation Act 2003 (the IGT Act) which empowers the IGTO to investigate certain actions taken by tax officials and systems established by the ATO, Tax Practitioners Board, and taxation laws. Importantly, however, these powers do not include investigating rules imposing or creating an obligation to pay an amount under a taxation law or rules dealing with the quantification of such an amount.
Inspector-General of Taxation role—the undertaking of systemic reviews
The IGTO's reviews have been the main focus of the office's work since its inception in 2003. Section 8 of the IGT Act provides for reviews to be initiated by the IGTO's own motion and at the direction of the minister; as well as via requests from either house of parliament, a parliamentary committee, the Commissioner of Taxation (the Tax Commissioner), and the Tax Practitioners Board.
The IGTO notes in its submission to the inquiry that, since 2003, it has completed 49 reviews in accordance with Figure 3.1 below.
Figure 3.1: Reviews completed since inception
Source: Inspector‑General of Taxation, Submission 5, p. 28.
To help guide the review function into the future, the IGTO notes that it is currently developing a framework outlining the principles of good tax administration, with the initial draft identifying the following principles:
fair and consistent treatment of taxpayers;
issues are managed proactively and responsively;
provision of accountability, transparency, and governance;
provision of certainty and consistency of taxation outcomes;
dealing respectfully, professionally, and collaboratively;
systems are simple and minimise costs; and
tax is paid and collected correctly.
Case study: The Inspector-General's review of the use of garnishee notices
On 9 April 2018, the Australian Broadcasting Corporation (the ABC) aired a Four Corners program which contained allegations by current and former tax officers about the ATO's inappropriate use of its power to issue garnishee notices.
A garnishee notice is a tax debt recovery tool which allows the ATO to recover taxpayer debts from third parties, such as banks and trade debtors. The IGTO notes that, if used inappropriately, these notices can severely affect the cash flows of more vulnerable taxpayers, such as small businesses and individuals.
Following the airing of the program, the IGTO commenced a review to investigate allegations that the ATO:
gave directions to staff to issue enduring garnishee notices in every case as a 'cash grab' towards the end of 2016‑17 financial year; and
set targets for staff and assessed their performance based on the level of debt collected.
In undertaking its review, the IGTO's investigation team visited four ATO sites, interviewed a range of staff, and accessed various systems, information, and records.
The IGTO found that problems did arise in certain localised pockets within the ATO, particularly in the Adelaide local site, but that these problems were 'anticipated and addressed by management once they became aware of them'.
The IGTO found that neither of the allegations made in the Four Corners program by current and former tax officials were sustained on the evidence it collected during its review.
In his submission to the committee, Mr Richard Boyle, a former Adelaide‑based ATO officer involved in the original disclosure, was critical of this outcome, stating:
For the Inspector-General of Taxation, as the institution tasked as being the main check and balance to any potential untoward or inappropriate behaviour of the Australian Taxation Office, to form this view despite being provided with extensive and exhaustive list of facts and information, is exceedingly disconcerting.
[This] represent[s] either a serious inadequacy of the Inspector-General of Taxation to conduct reviews of such a serious nature into the Australian Taxation Office, or worse, may indicate a deliberate obfuscation, complication or muddying of the facts which this author finds difficult to explain.
Importantly, as a result of the review, the IGTO identified a number of opportunities for improvement and made a number of recommendations which were agreed to, and implemented by the ATO.
Review process and operational guidelines
The following discussion provides a high-level overview of the systemic review process the IGTO undertakes. The IGTO has developed formal guidelines to aid this process, with each review divided up into the eleven discrete phases listed below:
Opening meeting and information access
Sharing information and views
Regular meetings and workshops
The IGTO notes that it identifies potential topics for review from a range of sources, such as its complaints handling service; consultation with externals stakeholders; media reports; ministerial and parliamentary direction; and direction from the chair of the Tax Practitioners Board and the Tax Commissioner.
When a decision is made to commence a review, the IGTO develops the terms of reference (the terms) which set out the scope of issues that are examined in the review. In developing the terms, the IGTO may consult with a range of stakeholders, such as other government agencies, taxpayers, tax professionals and their representative bodies.
As part of a review, the IGTO consults with the ATO and provides it with an opportunity to comment on factual matters in the terms before their publication. However, as an independent scrutineer, the IGTO notes that terms are ultimately its responsibility.
As part of the process, and before the publication of the terms, the Tax Commissioner provides formal authority to current and former staff to disclose information to the IGTO that is relevant to the review.
Once the terms are published, the IGTO may call for submissions to assist in identifying issues of most concern.
Opening meeting and information access
The review team within the IGTO's office meets with representatives from the ATO, to outline their role and the review process. The review team also shares observations on the issues that will be examined and processes and initiatives affecting those issues.
The ATO's team assists the review team to access of information, including providing timely access to buildings and staff. To promote the independence of the process, the IGTO notes that the review team has direct access to the ATO's systems, via provided terminals, to facilitate timely access to relevant information. Such access allows the review team to provide independent assurance of the evidence examined, while also reducing the demand on ATO resources.
Sharing information and views
The review team is authorised to seek information relevant to the issues examined in the review and may ask any tax officer to provide information which is relevant. Importantly, tax officers are authorised to provide information in response to such requests without offending the tax law secrecy provisions or privacy law. Further, tax officers are also authorised to proactively provide information to the review team if they reasonably believe it is relevant to the review.
Although the IGTO has compulsion powers, the IGTO states that the review team generally obtains relevant information without the need to invoke them.
Regular meetings and workshops
The review team and ATO team establish regular meetings to discuss the progress of the review and openly share observations and perspectives. At the request of either agency, workshops may be convened to improve the understanding of the issues and to identify issues needing to be discussed. Such workshops allow the review team to refine the scope of information requested, increase efficiency and effectiveness, and reduce resourcing impacts across the agencies.
External working group
The IGTO may convene a working group to improve understanding of the issues examined in the review, and identify practicable options for improvement. Such working groups may comprise external stakeholders, as well as senior representatives from the ATO and other government organisations.
Before issuing the preliminary draft report, the review team convenes a ‘sandbox’ meeting in which the IGTO's preliminary observations and potential recommendations are discussed. This provides both agencies with an opportunity to share their understanding of the issues, and test the basis for the IGTO's preliminary observations and potential recommendations.
Preliminary draft report
The IGTO provides the ATO with a copy of the preliminary draft report and an opportunity to comment. The report includes a description of the issues examined in the review, relevant policies, procedures and views as well as the IGTO's preliminary observations and potential recommendations.
If the IGTO proposes to make recommendations for government’s consideration, a copy of the preliminary draft report is also sent to Treasury’s nominated liaison officer to provide Treasury with an opportunity to comment.
The IGTO also provides the ATO with opportunities to meet and discuss the preliminary draft report and related potential recommendations; however, the IGTO notes that the final report is ultimately its responsibility.
Final draft report
The IGTO provides the ATO with an opportunity to comment on the final draft report to facilitate the identification of any unresolved concerns that require further consideration. The IGTO also provides a copy to Treasury to assist them in preparing their brief to the minister.
The IGTO provides the ATO with an opportunity to discuss and respond to the final draft report and its recommendations before the report is finalised. The ATO has 15 business days from the date of issuance of the final draft report to complete this process. Once a formal response is provided, the IGTO includes, within the body of the final report, the ATO's responses to each recommendation.
Following finalisation of the report, the ATO is invited to provide feedback on the process. The IGTO states that the aim of this phase is to improve the review process by identifying what worked well, what didn't work well, and to identify opportunities for improvement.
In addition to the ATO providing feedback to the IGTO on the review process, it also provides information on the proposed implementation plans for the proposed actions the ATO will take to implement the agreed recommendations.
Protocol between the Inspector-General and the Australian Taxation Office
In 2007, the IGTO and the Tax Commissioner signed a protocol to establish a framework for a productive, professional, efficient, and effective working relationship between their agencies.
The protocol commits both parties to establishing an open, honest and professional relationship that is built on mutual respect for each other’s role; and commits the ATO to the highest level of cooperation in assisting the IGTO acquit its role. It requires the IGTO to consult the ATO about proposed reviews he or she may undertake, and provide draft terms of reference and a reasonable opportunity for the ATO to comment.
In response, the ATO committed to providing background material and feedback, and to respond to specific information requests to help the IGTO scope its proposed reviews. Further, the ATO also committed to providing access to staff and buildings, and timely responses to requests for documents, access to systems, and other information.
The protocol requires the ATO to keep the IGTO informed of key corporate developments that are relevant to any review underway, and to ensure the IGTO is aware of issues related to items of current interest or focus.
The protocol allows for the ATO to provide written comments to the IGTO on issues papers, draft chapters, and recommendations prior to a final draft report being sent. Draft chapters and recommendations are discussed openly as part of this process, before a final draft report is sent to the ATO.
The IGTO is required to provide the ATO with a final draft report and an opportunity to make a submission on any actual or implied criticism.
Protocol between the Inspector-General and the Department of the Treasury
Also in 2007, the IGTO and the Department of the Treasury (the Treasury) signed a protocol outlining a co-operative working relationship to support both their respective roles, by establishing a framework for effective working arrangements and the timely sharing of information between their agencies.
The protocol states the IGTO is an operationally independent agency operating under the Financial Management and Accountability Act 1997 whose aim is to review systems established by the ATO to administer the tax laws; to review systems established by tax laws, to the extent those systems deal with administrative matters; and to report on those reviews to Treasury ministers.
The protocol notes the role of the Treasury as the principal source of advice to Treasury ministers on taxation, excise, and superannuation policy issues, and the design of relevant legislation.
The Treasury also has the portfolio responsibility to provide guidance to the IGTO on the operation of the IGT Act. Where the IGTO wishes to obtain independent legal advice on the interpretation of the IGT Act, the IGTO must provide the Treasury with:
a reasonable opportunity to consult on the proposal to seek advice;
a draft copy of the request for advice;
a reasonable opportunity to consult on the matter prior to the advice being finalised, including consultation with the IGTO's legal services provider; and
To support the Treasury in its role, the protocol requires the IGTO to provide the Secretary to the Treasury with timely information and, where necessary, briefings on any significant issues related to the IGTO’s activities. Similarly, the Treasury is required to keep the IGTO informed of government decisions and other developments relevant to the IGTO’s activities.
Taxation Ombudsman role—the investigation of taxpayer complaints
Since 2015, a core function of the IGTO has been to investigate action that is the subject of a complaint. The IGTO provides a free, independent, and impartial complaints service to all taxpayers, whether directly or through their representatives. The IGTO states that the investigation of complaints provides unique and valuable insights into the administrative practices of the ATO and Tax Practitioners Board, and their service delivery.
The IGTO notes that, for many taxpayers, particularly more vulnerable individuals, the IGTO is viewed as a final avenue of recourse. In a large number of cases, taxpayers have already made attempts to resolve their matter directly with the ATO or the Tax Practitioners Board (the agencies); however, the agency has not been able to resolve their matter, or they remain dissatisfied with either agency’s investigation.
In approaching the IGTO, taxpayers and tax practitioners often raise concerns about:
not understanding the agency’s communications or actions and the options that may be available to them;
the impacts of delays by the agency in completing an administrative action, for example, the delay in processing a form or return or in completing a compliance activity. These delays can cause significant financial, economic and health impacts on taxpayers and tax practitioners; and
the multiple interactions that are required to resolve an issue or complaint and the difficulties in navigating numerous areas within the agency and the tax system.
These concerns are further outlined in Figure 3.2 below.
Figure 3.2: The main reasons taxpayers complain to the IGTO
‑General of Taxation, Submission 5, p. 64.
Since May 2015, approximately 28 per cent of complaints have been lodged by businesses and the remaining 72 per cent mostly by individuals.
The IGTO states that a large majority of complaints are lodged without any representation, with only 23 per cent and 13 per cent of complaints lodged by business and individuals, respectively, being lodged by a representative. Further, only 43 per cent of the representatives for individuals are tax practitioners, accountants or lawyers, with the remaining individuals being represented by family members or friends. See Figure 3.3 below.
Figure 3.3: Types of complainants and representation
Source: Inspector‑General of Taxation, Submission 5, p. 62.
The IGTO receives complaints from the community through a number of channels, but primarily through its website and contact centre. Complaints are also referred to the office by other government agencies, including the Commonwealth Ombudsman, the Australian Small Business and Family Enterprise Ombudsman (ASBFEO) and parliamentarians. Figure 3.4, below, provides further information on the number of referrals received from other agencies for the 2018-19 financial year.
Figure 3.4: The number of referrals from other agencies in 2018‑19
Source: Inspector General of Taxation, Submission 5, p. 65.
Case study: Ms Helen Petaia's complaint to the IGTO
Ms Helen Petaia's submission is based on her personal experience with the IGTO, where she made a complaint in relation to comments made by the Tax Commissioner during a Senate estimates hearing.
Ms Petaia stated that, in her case, the IGTO was able to effectively influence the ATO through chronologically mapping out relevant facts and events while undertaking its investigation. She summed up her experience as follows:
The IGT office, their staff and their leadership have excelled in their service. They have listened and they have been across the details down to the micro. They have cautioned and expressed fairness to all sides of the arguments. They have been intelligent; they have been practical; they have been unbiased; they have been diligent and resourceful. They have been unbelievably human.
Ms Petaia acknowledges that, if the IGTO was to undertake more broadly the same level of analysis that was undertaken in her case, considerable resourcing would be required. She recommends an increase in funding to expand the services provided by the IGTO.
Ms Petaia believes that services provided by the IGTO could save hundreds of thousands of dollars in legal fees for small business, and may even eliminate the need to undertake legal action.
Ms Petaia states that, due to the IGTO's team's in-depth knowledge and extensive expertise, they can streamline resolution processes by focusing on relevant facts and issues, and, hence, provide quicker outcomes to complainants; a vital outcome for small businesses. On this point she stated:
Speaking as a small business owner, the IGT is the best-kept secret for small business owners who find themselves in frustrating disputes with the ATO.
Inspector-General's discretion to not investigate a complaint
Although rarely exercised since assuming responsibility for the investigation of taxpayer complaints in 2015, the IGTO has discretion to not investigate a complaint when it considers that:
the complaint is frivolous or vexatious or was not made in good faith;
the complainant does not have a sufficient interest in the subject matter of the complaint;
an investigation, or further investigation, of the action is not warranted having regard to all the circumstances;
the complainant has not yet raised the complaint with the Tax Commissioner or the Tax Practitioners Board;
the action came to the complainant’s knowledge more than 12 months before the complaint was made; or
the complainant has not exercised a right to cause the action to which the complaint relates to be reviewed by a court or by a tribunal constituted by or under a law of the Commonwealth.
Complaints management policies and procedures
The IGTO has established complaints management policies and procedure documents which set out its approach to complaints management. These include the Complaints Handling Operational Guidelines; Operational Instructions; and internal procedural documents, such as the Complaints Work Practices Manual and Unreasonable Conduct Management Policy.
The IGTO categorises all approaches made to it on a scale from ‘Category 0’ to ‘Category 5’ to indicate the resources needed for their resolution. Category ‘0’ to ‘2’ cases are resolved internally without involving the ATO, whereas category ‘3’ to ‘5’ cases require the ATO's involvement and are raised as formal complaint investigations. Category 4 cases warrant direct and ongoing IGTO involvement in the handling of the case, and Category 5 cases require the senior executive service officers responsible for the delivery of programs or functions that are the subject of the complaint to be involved in the resolution of the matter.
An investigation invokes the IGTO's legislative powers of information gathering and allows both agencies to share information about the case, which would otherwise be prohibited by the relevant secrecy provisions.
Where the IGTO decides to investigate a complaint, the case officer provides official notification to the ATO's Complaints Unit by way of an investigation notice. This notice helps to highlight the client’s concerns and preferred outcomes in the relevant tax administrative framework. In particular, it sets out:
the client’s experience, concerns and preferred (or agreed) outcomes as well as the supporting information and documents provided by the client to the IGTO, where authority to do so has been provided; and
the case officer’s analysis of the key administrative issues that need to be addressed and potential options for resolution, based on the information available at that time.
The case officer sends such investigation notices to a single designated email address within the Complaints Referral Unit, to ensure visibility and to allow for its formal registration as a complaint on the system. The Complaints Referral Unit then schedules an early assessment meeting with both the IGTO's and ATO's case officers to reach a common understanding of the issues; the potential options for resolution; and the types of resources needed.
After an early assessment meeting has been held, progress assessment meetings can be scheduled, as necessary, to:
improve the case officers' understanding of the client's concerns, and discuss any additional issues raised and subsequent communications with the client;
resolve any remaining issues before agency responses are formalised;
resolve concerns with either agency's involvement in, or handling of, the complaint; and
identify opportunities to improve the broader administration of the tax system.
The ATO provides the IGTO's complaints handling officers with direct access to their staff and systems to facilitate the timely resolution of complaints. This access allows these officers to provide independent assurance to their clients.
The IGTO's case officers resolve investigations by providing independent third-party assurance of the actions taken by the ATO, as well as identifying opportunities for improvement in tax administration. The ATO is accountable for any remedial actions flowing from a complaint investigation, and the ATO is encouraged to communicate outcomes directly with the client. If, however, direct communication is not be welcome, the IGTO's case officer may contact the client to inform them of the outcome of the investigation and advise them of the ATO's intention to communicate, and what can be expected during such a communication.
If the client is unhappy with the outcome of the investigation, they are provided with an opportunity to seek an internal review of the IGTO's decision.
Suggestions to improve the performance of the IGTO's investigative functions
The IGTO's views and suggestions
In the IGTO's submission to the inquiry, it made a number of observations and recommendations related to its investigative functions. Specifically, the IGTO recommended:
the protections available to all those who disclose information to the IGTO be strengthened, regardless of whether the disclosure relates to a complaint or systemic review. The IGTO believes this should include protections from statutory, administrative, and professional conduct sanctions and ensure protection from reprisal where information is provided in good faith;
the rights of tax officials who are interviewed during investigations undertaken by the IGTO be clarified and that protections afforded to them be strengthened;
the governance arrangements related to the investigations of complaints be improved to ensure that non-binding recommendations made by the IGTO in respect of a complaint be formally responded to within specified times frame and, where a recommendation is not accepted, reasons are provided;
the statutory scope for the review function be clarified to ensure that matters relating to the quantification and collection of taxation, such as penalties, be included within the function;
the IGT Act be better self-contained and not simply refer to the Ombudsman Act 1976. The IGTO believes this would not only clarify the legislative powers and functions of the IGTO but also provide operational clarity;
more formal arrangements between the IGTO and Australian Tax Clinics be introduced to facilitate a seamless delivery of services to the community;
being empowered to award an amount of compensation, or reasonable costs, to complainants where an IGTO investigation finds that action taken by the ATO or the Tax Practitioners Board has caused loss or damage, or where they have failed to take reasonable action leading to loss or damage; and
improve the model for inter-agency collaboration to permit joint investigations. The IGTO believes this would streamline the investigation process and permit sharing of information and expertise in appropriate circumstances.
Other views and suggestions
Improve community awareness
A number of inquiry participants raised the issue that the IGTO is not well known within the community. For example, the ASBFEO notes in its submission that an investigation it undertook in 2018 found that small business owners do not know the role of the IGTO. Given this, the ASFBEO recommends that the IGTO be better publicised and that it clearly indicate that its services are not limited to non-commercial taxpayers.
The former IGTO, Mr Ali Noroozi, also recognised this as an issue in his valedictory speech. He recommends the IGTO be better promoted and renamed the Taxation Ombudsman to make it more identifiable amongst those who need assistance with their disputes, such as small business and individuals.
Complementing the above, Chartered Accountants Australia and New Zealand (CAANZ) recommends the IGTO update its website to improve clarity and streamline the explanation of its complaints handling process.
Expand and clarify investigative powers
Some submitters indicated there was confusion within the community regarding the delineation of functions of the various organisations providing services to them. For example, CAANZ indicated there is a lack of clarity around the respective functions of the IGTO and the ASFBEO in relation to small business and family enterprises, and that this has caused confusion within the community.
The Law Council of Australia (the LCA) also recognised this issue and, in its submission, recommended the IGTO become the sole scrutineer of the ATO, amalgamating the roles of various scrutineers into one body.
The ASFBEO thought there was scope for service delivery improvement for small business and recommended that the IGTO create a small‑business division led by someone with in‑depth small business experience.
In her submission, Ms Joanne Hambrook also called for more experienced staff with investigative skills. She recommended the IGTO also have a guiding board consisting of experienced professionals, such as retired judges and lawyers, to assist it.
The Institute of Public Accountants (the IPA) noted that the IGTO can only recommend a course of action in relation to its investigation of complaints. The IPA believes there may be merit in providing the IGTO with the power to direct the ATO in relation complaints, including awarding compensation when a loss has been incurred by a complainant.
In contrast to the above position, the IPA does not see the IGTO's lack of power to direct the ATO in relation to its systemic reviews as an issue. This is because it believes the existing model is working as intended, and all reviews and recommendations are on the public record and, therefore, there is full transparency around every matter raised and each party’s respective position.
Ms Hambrook believes the IGTO could be more proactive in referring offences under its legislation to the Australian Federal Police for further investigation and potential prosecution by the Commonwealth Director of Public Prosecutions.
The committee considers, based on the evidence received, the IGTO needs to be better publicised, especially its role as the Tax Ombudsman. Although the number of complaints received by the IGTO has increased markedly since the function was transferred in 2015, a number of submissions noted that this function is still not well known within the community, especially amongst small business owners who would likely benefit from utilising its services.
The committee notes the confusion within the community around the respective functions of the IGTO and the ASFBEO in relation to small businesses and family enterprises. As part of a broader information campaign, the committee suggests the respective roles of each entity be clarified.
The committee agrees in principle with the IGTO, that protections available to individuals, including tax officials, who disclose information to the IGTO need to be strengthened, regardless of whether the disclosure relates to a systemic review or the investigation of an individual complaint.
The committee considers that in cases where the IGTO has made non-binding recommendations which have not been accepted by the ATO or the Tax Practitioners Board, a rationale for not accepting the recommendations ought to be provided in a timely manner by the ATO or the Tax Practitioners Board.
The committee is concerned that various offence provisions, such as those designed to prevent the victimisation of people who assist the IGTO, are not being adequately enforced, and that there is confusion around which entity is responsible for their administration.
The committee believes the interactions between the IGT Act and the Ombudsman Act can be improved, and the current arrangement creates confusion and is difficult to administer. The committee agrees with the IGTO that a review of the existing legislative framework would be beneficial and could clarify the legislative powers and functions of the IGTO. The committee also notes that such a review should include an assessment of the necessity of the exclusion in subsection 7(2) of the IGT Act regarding rules and quantification.
The committee notes the recommendation by the IGTO that more formal arrangements between it and the Australian Tax Clinics should be introduced, and that inter‑agency collaboration be enhanced to permit joint investigations and the sharing of information and expertise.
The committee recommends the Australian Government better publicise the IGTO's ombudsman function through the development of a marketing campaign. Such a campaign should, amongst other things, clarify how the IGTO's role interacts with other ombudsmen, such as the Small Business and Family Enterprise Ombudsman.
The committee recommends the Australian Government consider strengthening protections available to individuals who disclose information to the IGTO, regardless of whether the disclosure is in relation to a complaint investigation or systemic review.
The committee recommends the rights of tax officials who are interviewed during investigations undertaken by the IGTO be clarified, and that protections afforded to them be strengthened. This includes providing officials the legal right to choose whether or not they have other persons present when providing information.
The committee recommends the Australian Government ensure that non‑binding recommendations made by the IGTO, in respect of a complaint, be formally responded to within a reasonable time frame and, where a recommendation is not accepted, rationale for the non-acceptance be provided.
The committee recommends the Australian Government clarify which entities are responsible for investigating and prosecuting offences under the IGT Act, such as those created under section 39.
The committee recommends the Australian Government review the IGT Act and its interactions with the Ombudsman Act, with the objective of improving the IGT Act's clarity. Such a review would also include an assessment of the necessity of the exclusion in subsection 7(2) of the IGT Act regarding rules and quantification.
The committee recommends the Australian Government consider the benefits of introducing more formal arrangements between the IGTO and Australian Tax Clinics, as well as improving the model for inter-agency collaboration to permit joint investigations.