Insufficient attention is given to early interactions with the ATO in the dispute resolution process, Mr Heinemann said.

“Get in early [and] make sure that there is a full response early on,” he said. “There is only one chance to make that first impression.

“The difficulty is often that those initial letters [from the ATO] may be too polite and don’t quite trigger the necessary urgency from the client and the adviser.”

Mr Heinemann also said practitioners should not allow their client to ignore the ATO’s request or timeframe for response, or provide a “sketchy or long-winded” response.

Practitioners and their clients should remember the ATO’s function is to administer the SIS Act, not to seek justice or prevent hardship, he added.