Date posted: 12/11/2025

Submission on PUB00500c – Shortfall penalties – reductions and other matters

CA ANZ’s feedback on the draft interpretation statement.

The statement provides comprehensive guidance on the reductions, increases, and operational matters relating to shortfall penalties imposed under sections 141A–141E of the Tax Administration Act 1994. The statement covers:

  • When and how shortfall penalties may be reduced (for previous behaviour, voluntary disclosure, disclosure of a tax position, or temporary shortfall)
  • The limitation on reductions and how combinations are handled
  • The penalty cap ($50,000) and when it applies
  • When penalties may be increased for obstruction
  • The rules for multiple penalties, assessment, payment, and disputes
  • Numerous practical examples and summary tables to illustrate how the rules apply in real scenarios.

CA ANZ supports the publication of PUB00500c IS, noting that the statement is comprehensive, with the worked examples and summary tables providing valuable real-world context.

CA ANZ also offers several suggestions to further improve the accessibility and practical value of both the statement and the accompanying draft Fact Sheet.