Ryan has recently disposed an intangible asset he developed and applied the 12 months 50% discount rule notwithstanding the fact that he only held it for 11 months.

Ryan was initially liable to pay $500,000 and received the notice of assessment on 1 June 2019. Ryan subsequently received an amended notice of assessment on 1 May 2021 to pay $1,000,000 and interest and penalties. As Ryan did not have access to additional funds in the short term, Ryan was only able to pay the ATO debt 1 January 2022.

Question

Advise Ryan whether the ATO can issue an amended notice of assessment and whether he can challenge the new liability imposed.

Assuming Ryan cannot challenge the new liability imposed, advise what administrative penalty and interest charges Ryan will be subject to and what information need to be provided to request a penalty and interest charge reversal.

Answer rating: 100% (QA)

Advise Ryan whether the ATO can issue an amended notice of assessment and whether he can challenge the new liability imposed Yes the ATO can issue an ... View the full answer