Date posted: 12/02/2026

Submission on PUB00501 Shortfall penalty for taking an abusive tax position

CA ANZ’s feedback on the draft interpretation statement and fact sheet.

PUB00501, together with its accompanying fact sheet, provides a comprehensive explanation of the “abusive tax position” shortfall penalty under section 141D(7) of the Tax Administration Act 1994.

CA ANZ supports the intent and overall clarity of PUB00501 and its fact sheet, and has identified several technical amendments and areas where further clarification would enhance precision and usability.