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    2. Public rulings and practice directions
    3. Public Ruling TAA017.1.1 Reassessments decreasing liability for tax

    Reassessments decreasing liability for tax

    Public Ruling TAA017.1.1
    Issued
    20 November 2025
    Download PDF

    A public ruling, when issued, is the published view of the Commissioner of State Revenue (the Commissioner) on the particular topic to which it relates. It therefore replaces and overrides any existing private rulings, memoranda, manuals and advice provided by the Commissioner in respect of the issue(s) it addresses.

    Where a change in legislation or case law (the law) affects the content of a public ruling, the change in the law overrides the public ruling—that is, the Commissioner will determine the tax liability or eligibility for a concession, grant or exemption, as the case may be, in accordance with the law.

    What this ruling is about

    1. This public ruling sets out the basis on which the Commissioner will exercise the discretion to make a reassessment decreasing liability for primary tax under s.17(1) of the Taxation Administration Act 2001 (Administration Act).
    2. Section 17(1) of the Administration Act provides that the Commissioner may make a reassessment of a taxpayer’s liability for tax at any time, subject to the time limitations in ss.21 and 22 of the Administration Act.
    3. This public ruling does not apply to:
      1. reassessments under s.17 of the Administration Act that increase or do not change liability for primary tax1
      2. reassessments that must be made under s.18 or s.19 of the Administration Act.

    Purpose of a reassessment

    1. The objection and appeal regime is the primary means of review of liability for tax under the Administration Act. This requires the taxpayer to lodge an objection within 60 days of being given an assessment notice or any longer period approved by the Commissioner.2
    2. The reassessment discretion under s.17 of the Administration Act provides a taxpayer who has a reasonable lack of awareness that an assessment was incorrect within time to exercise their objection rights an opportunity to have the assessment corrected. For administrative convenience, a taxpayer may also request a reassessment under s.17 of the Administration Act rather than lodge an objection for a clear error or omission in the assessment. However, the Commissioner is under no obligation to make the reassessment.
    3. The discretionary power to make a reassessment outside the objection and appeal framework cannot be used to obtain de facto review rights or reopen questions of law.

    Conditions for a reassessment

    1. The Administration Act sets out the following conditions for a reassessment:
      1. The Commissioner can not be compelled to make a reassessment decreasing liability for tax.3
      2. A decision not to make a reassessment of a taxpayer’s liability for tax is a non-reviewable decision.4
      3. A reassessment must be made in accordance with the legal interpretations and assessing practices applied by the Commissioner for assessing liability for tax in similar circumstances when the original assessment of the taxpayer’s liability for tax was made.5
      4. A reassessment decreasing liability for tax, or a request by a taxpayer for a reassessment, must be made within five years after the notice for the original assessment was given, subject to limited exceptions.6

    Ruling and explanation

    1. The Commissioner decides whether or not to make a reassessment decreasing liability for tax under s.17 of the Administration Act on a case-by-case basis having regard to all the relevant facts and circumstances of each case.
    2. In deciding whether to make a reassessment decreasing liability for tax, the Commissioner will consider the following matters.

    Mandatory requirements for making a reassessment

    1. In exercising the Commissioner’s discretion, the following requirements must all be satisfied:
      1. The taxpayer must establish that the assessment was not correct or is no longer correct. The Commissioner must be satisfied that there are grounds for reassessment decreasing liability due to an error, omission or change.
      2. The grounds for reassessment must arise in accordance with the legal interpretations and assessing practices applicable at the time of the original assessment.
      3. The reassessment, or the request by the taxpayer for a reassessment, must be made less than five years after the notice of the original assessment was given.

    Discretionary factors for making a reassessment

    1. If the mandatory requirements are satisfied, the Commissioner will consider the following discretionary factors:
      1. the explanation for and circumstances relating to the error, omission or change and any delay in seeking to correct the assessment
      2. the proper and orderly administration of the relevant revenue law and the Administration Act
      3. any prejudice to the taxpayer if a reassessment is not made
      4. any other relevant considerations raised by the taxpayer.

    Other matters

    1. Notwithstanding paragraphs 8 to 11, the Commissioner will generally make a reassessment under s.17 of the Administration Act that decreases liability for tax imposed by an assessment in the following circumstances:
      1. reassessments that give effect to changes of ownership or taxable value under the Land Tax Act 2010
      2. reassessments that arise from a decision of the Commissioner to approve an application from an earlier date7
      3. reassessments that give effect to an approval by the Commissioner of an application by a taxpayer for an exemption or concession under an express provision of a revenue law.8

    Request for reassessment

    1. A taxpayer may request a reassessment in writing or through QRO online. The request must be made not more than five years after notice of the original assessment was received by the taxpayer.9

    Date of effect

    1. This public ruling takes effect from 1 December 2025.

     

    Simon McKee
    Commissioner of State Revenue
    Date of issue: 20 November 2025

    References

    Public Ruling Issued Dates of effect
    From To
    TAA017.1.1 20 November 2025 1 December 2025 Current

    Footnotes

    1. The Commissioner’s practices for remission of unpaid tax interest and penalty tax are set out in Public Ruling TAA060.1 and Public Ruling TAA060.2 respectively.
    2. Section 65 of the Administration Act
    3. Section 17(4) of the Administration Act
    4. Section 17(5) of the Administration Act
    5. Section 20(1) of the Administration Act
    6. Section 21 of the Administration Act, with exceptions in section 23
    7. For example, a decision to register a charitable institution from a date before the date of application under s.149G(3) of the Administration Act, and an order to exclude a person from grouping from a date before the order under s.74(6) of the Payroll Tax Act 1971
    8. For example, an application for exemption from land tax under s.76 of the Land Tax Act 2010 and an application for a transfer duty home concession under s.95 of the Duties Act 2001
    9. Section 21 of the Administration Act