ATO claims a lot of thngs but ends up in Court and loses most of the time. For example they lost to News Corp and had to pay them $800 Million. They have lost to a lot of other companies as well and that's why they are trying the mediation pathway. As you probably know Mediation is set down for 25 - 27 August but they must meet 21 days before that time.
ATO resolution, page-12
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