The draft interpretation statement outlines the definition of “gross carelessness” under s 141C(3) as conduct that, in all relevant circumstances, indicates a significant disregard for possible consequences.

CA ANZ recommends the following improvements to the final statement:

• Add a one-page decision-tree outlining tax position, shortfall, s 141C factors (experience, warnings, significance, etc.), risk assessment, and fallback to s 141A if needed.
• Present factor analysis in a table with extra columns for case references and practical indicators (e.g., ignored warnings, untrained staff handling major transactions, rapid sales linked to prior claims).
• Include a boxed note that the test is objective and taxpayer intent does not apply; deliberate actions fall under s 141E (evasion), not s 141C.
• Hyperlink relevant cross-references and provide a “Related documents” panel up front.
• Add a brief glossary of key terms.
• Streamline example formatting: each Tauira should conclude explicitly and, when useful, list decisive factors.
• Insert a note on sequence: reductions and limitations are applied before cap/outcome as per PUB00500c.

CA ANZ also offers further recommendations to strengthen the accompanying draft Fact Sheet.