Hi Tokyo,
The ATO has agreed to no further recovery action beyond the $34M that was paid pending the matter being settled. The issue as I understand is that the ATO have yet to determine the objection, hence the matter cannot be tested before the courts.
The real question is why has the ATO not determined the objection. After 18 months, you would think that they could issue a notice disallowing the objection. Why the delay? Maybe the ATO is not confident on its position and does not want the matter to go to the courts.
Maybe the ATO is hoping that the MCC matter is resolved, so it can settle and save some face. That is my speculation. Otherwise disallow the objection and let the courts decide.
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