The ATO's claim for $18m tax shortfall, excluding penalties, is essentially a claim that there was circa $60m of additional income (or non-deductible expenditure) between 2011 to 2015.
Also, assuming that the income tax returns were lodged by the company in the ordinary course (i.e. on time, or thereabouts), the ATO would be out of time to amend the 2011 and 2012 assessments under section 170(1) of the ITAA 1936. That would then leave the 2013-2015 years as the only ones where the ATO isn't statute barred, unless their alleging that there has been fraud or evasion on the part of the company in lodging its ITRs...
Will be an interesting time to come!
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