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If we disagree with a return you've filed, we can start the disputes process. This is called a Commissioner-initiated dispute.

The disputes process is designed to resolve disagreements as quickly as possible by: 

  • identifying all issues early
  • full disclosure of the facts and evidence
  • consultation between us.

Your rights and responsibilities throughout the Commissioner-initiated disputes resolutions process are outlined in Standard Practice Statement 16/05. 

SPS 16/05 Disputes resolution process commenced by the Commissioner of Inland Revenue


If you want to start a dispute this is called a taxpayer-initiated dispute and follows a slightly different process. 

When you start the disputes process

Do you need professional advice?

We recommend that you get independent advice from an accountant or other professional tax advisor if you want to go ahead with your dispute. This is especially important if complex issues are involved. 

Because of the nature of the disputes process, we cannot fill in or draft any notices or forms on your behalf. However, we can help by explaining things like the forms you need and time limits that apply, or by referring you to our booklets and guides on the disputes process.