Chapter 1Introduction and background
Referral of the inquiry
1.1The Treasury Laws Amendment (Tax Accountability and Fairness) Bill 2023 (the bill) was introduced into the House of Representatives on 16 November 2023.
1.2On 30 November 2023, the Senate referred the provisions of the bill to the Senate Economics Legislation Committee for inquiry and report by 18 April 2024.
1.3On 26 March 2024, the Senate approved an extension to report to 10 May 2024 for the inquiry.
Purpose of the bill
1.4The purpose of the bill is to amend taxation, taxation administration, and related legislation to enact a range of measures.
1.5The bill proposes to introduce two distinct categories of reforms:
Schedules 1 to 4 introduce tax and whistleblower reforms which are packaged as a response to the PwC tax leaks scandal.
Schedule 5 introduces reforms to increase the amount of tax paid on offshore gas exports through changes to the petroleum resource rent tax deductions cap.
1.6The intent of the bill was explained in the second reading speech by the Assistant Treasurer and Minister for Financial Services, the Honourable Stephen Jones MP, on 16 November 2023. The Assistant Treasurer stated that Schedules 1 to 4 aim to curb tax practitioner misconduct in the wake of the PwC tax leaks scandal and rebuild public confidence in the tax system.
1.7The Assistant Treasurer stated that Schedule 5 aims to limit the proportion of petroleum resource rent tax (PRRT) assessable income that can be offset to a maximum deduction of 90 per cent. In effect, this schedule would ensure that the offshore liquefied natural gas industry pays more tax sooner.
1.8A detailed comparison of the key features of new laws and current laws relating to Schedules 1 to 4 is provided in the explanatory memorandum (the EM).
1.9A detailed comparison of the key features of the new law and current law relating to Schedule 5 for the petroleum resource rent tax is outlined in the report on the Treasury’s review of the PRRT,which was provided as an attachment to the EM.
1.10Each of the bill’s five schedules are outlined below.
PwC Response—response to tax adviser misconduct by PwC and its partners
1.11The PwC response arose because of misconduct by accounting, auditing, and consulting firm PwC and one of its partners, Mr Peter Collins.
1.12From 2013 to 2016, Mr Collins received confidential information from consultations with the Treasury and through his engagement with the Board of Taxation in relation to Australia's forthcoming anti-avoidance tax laws. The confidential information, which included new rules to stop tax avoidance by multinational companies, was subsequently shared.
1.13These matters came to light in January 2023 when a Tax Practitioners Board (TPB) media release revealed that it had deregistered a former PwC partner, MrPeter Collins, for breaching the code of professional conduct in the Tax Agent Services Act 2009 (TAS Act). The TPB investigation found that Mr Collins had intentionally shared confidential information obtained from Commonwealth agencies with PwC partners and staff, and that PwC had failed to properly manage conflicts of interest when this confidential information was shared.
1.14On 6 August 2023, the Government announced a package of reforms intended to curb tax adviser misconduct, in response to the PwC tax leaks scandal. In announcing the reforms, the Government stated that the scandal had shown that some of Australia’s current regulatory frameworks are not fit for purpose.
1.15The bill responds to the PwC matter by proposing amendments to several Acts to implement measures contained in four schedules:
Schedule 1—PwC response—Promoter penalty law reform;
Schedule 2—PwC response—Extending tax whistleblower protections;
Schedule 3—PwC response—Tax Practitioners Board reform; and
Schedule 4—PwC response—Information sharing.
1.16Schedules 1 to 4 form part of the broader whole of Government PwC response coordinated by the Treasury. The Treasury noted that, in addition to this bill being introduced to Parliament in 2023, several other PwC response measures are subject to consultation through 2024.
Schedule 1—PwC response—Promoter penalty law reform
1.17Misconduct by tax advisers has the potential to cause significant harm to Australia’s tax system by eroding national tax receipts and undermining public confidence in the tax system.
1.18The promoter penalty laws in the Taxation Administration Act 1953 (TA Act) were introduced in 2006 to deter the promotion of tax avoidance and tax evasion schemes following the prevalence of such schemes in the 1990s.
1.19This schedule addresses two main areas of concern. First, the current penalty provisions are now insufficient to deter tax practitioner misconduct. Second, since the promoter penalty provisions were first introduced, the nature of tax promoter activity has evolved as tax exploitation schemes have become more bespoke and complex, often operating across jurisdictional boundaries.
1.20Schedule 1 would broaden the scope of tax promoter penalty laws to:
amend the TA Act to increase the period of time the Commissioner of Taxation (the Commissioner) has to bring an application for civil penalty proceedings to the Federal Court of Australia (the Court);
increase the maximum penalty applicable; and
expand the application of the promoter penalty laws.
Definition of tax exploitation scheme
1.21Currently, a tax exploitation scheme is defined as a scheme entered into or carried out for the sole or dominant purpose of obtaining a ‘scheme benefit’. Generally speaking, an entity gets a scheme benefit where a scheme is in place, and if the scheme was not in place, either the entity would be liable for more tax or the Commissioner would have to pay or credit a lesser amount to the entity.
1.22The Multinational Anti-Avoidance Law (MAAL) and the Diverted Profits Tax (DPT) provisions apply to a scheme where a person is a part of the scheme for at least one principal purpose of either obtaining a tax benefit or obtaining a tax benefit and reducing tax liability under a foreign law, where it is not reasonably arguable that these benefits are legally available.
1.23The application of these provisions means that the Commissioner is restricted to targeting the promotion of schemes to multinational enterprises, where that promotion occurs in relation to schemes which seek to avoid the attribution of profits to the Australian arm of the enterprise, eroding the corporate tax base.
1.24However, there is no prohibition on promoters using ATO rulings, other than product rulings, to mislead clients by asserting that a scheme has ATO endorsement while implementing the scheme materially differently than as described in the ruling.
1.25Schedule 1 would amend this definition to ensure it captures schemes that are, or would be if implemented, subject to the Income Tax Assessment Act 1936 (ITA Act).
1.26The MAAL is an extension of Australia's general anti-avoidance rules. This law only applies to Significant Global Entities (SGEs) and works to ensure that these multinational enterprises pay their fair share of tax on the profits earned in Australia.
1.27The DPT ensures the tax paid by multinational enterprises properly reflects the economic substance of their activities in Australia. It aims to prevent the diversion of profits offshore through contrived arrangements. Like the MAAL, it only applies to SGEs.
Definition of tax scheme promoter
1.28Under the current laws, an entity can only be considered a promoter of a tax exploitation scheme if the entity, or an associate of the entity, receives consideration in respect of the marketing or encouragement of that scheme. This concept of receiving consideration restricts the Commissioner’s ability to apply the promoter penalty laws where a promoter receives a benefit that does not come directly from a client, such as increasing the promoter’s client base.
1.29Schedule 1 would broaden the definition of promoter to include entities that have received a benefit, rather than only entities that have received consideration, in respect of the marketing or growth of interest in a scheme. This would allow the Commissioner to seek an order against promoters that have received benefits which are intangible, less obvious, or disguised compared to situations where ‘consideration’ is received.
Time limitation for commencing proceedings
1.30Under the current laws, a four-year limitation period applies for proving conduct has contravened the promoter penalty laws. Where the Commissioner wishes to apply to the Court for an order that an entity’s conduct contravened the promoter penalty laws, the Commissioner must do so within four years from the time the alleged conduct last occurred. Schedule 1 would extend this timeframe to six years.
1.31The four-year limitation has often been shown to constrain the ability of the Commissioner to successfully enforce the promoter penalties. This is because audits revealing the promotion of avoidance and evasion schemes often occur after the four-year limitation period has expired, and the Commissioner and the ATO generally require significant time to investigate and gather evidence prior to making an application to the Court.
1.32Currently, the law does not require a tax exploitation scheme to have actually been implemented for a penalty to be imposed; offences involving the promotion of tax exploitation schemes are not subject to a time limitation period. However, this has only been applied where the schemes have actually been implemented.
1.33Schedule 1 contains amendments so that schemes which would involve tax evasion if implemented would fall under an exception to the time limitation period. This would effectively mean that the time limitation periods would not apply where the Commissioner seeks penalties for the promotion of tax evasion schemes that have not been implemented.
Penalties for misrepresenting schemes which are not implemented
1.34For offences involving the misrepresentation of a scheme’s conformity to product rulings, the law does not specifically state that a penalty may be imposed if a scheme was not implemented.
1.35Schedule 1 would clarify how the promoter penalty laws apply to schemes which are promoted as conforming with a public, private or oral ruling, where the scheme materially differs from the ruling. It would make clear that these laws apply before, during and after the implementation of such schemes. The amendments also ensure that penalties apply to the promotion of such schemes even if they are never implemented.
1.36These amendments also respond to a decision of the Federal Court and a decision of the Full Federal Court, where it was held that it was necessary for a scheme to actually be the subject of a product ruling in order for the promoter penalty provision to apply. The amendments would mean that a scheme which was wrongly promoted as conforming with a product ruling does not need to be the subject of that product ruling in order for the promoter penalty provisions to apply.
Promoter penalty provisions
1.37The promoter penalty provisions in Division 290 of Schedule 1 to the TA Act were introduced in 2006 and have since remained unchanged in terms of penalty units. These penalties have not kept pace with other developments in Australian law, particularly relating to maximum civil penalties in comparable legislation including both the Competition and Consumer Act 2010 and the Corporations Act 2001.
1.38At the time of writing, the maximum civil penalty for an offence under the promoter penalty laws is the greater of:
5000 (currently $1.57 million) penalty units for an individual or 25 000 (currently $7.8 million) penalty units for a body corporate; or
two times the consideration received or receivable by the entity (and associates of the entity) in respect of the scheme.
1.39Schedule 1 would increase the maximum penalty to the greater of:
5000 penalty units for an entity other than a body corporate or significant global entity (SGE) or 50 000 penalty units for a body corporate or SGE; or
three times the benefits received or receivable, directly or indirectly, by the entity and associates of the entity in respect of the scheme.
1.40Schedule 1 also introduces an alternative maximum penalty for bodies corporate and SGEs which would cap the penalty units to an amount equivalent to 10 per cent of their aggregated turnover for the most recent income year ending before the relevant breach occurred, or began occurring, capped at 2.5 million penalty units.
Schedule 2— PwC response—Extending tax whistleblower protections
1.41The PwC tax leaks scandal exposed shortcomings in Australia’s regulatory frameworks, including limitations on the abilities of regulators to receive and share information from whistleblowers. These limitations have arbitrarily and negatively constrained the integrity of the taxation system.
1.42Under the current laws, whistleblower protections apply when individuals make a disclosure of information to the Commissioner for the purposes of taxation law. However, whistleblowers currently have no protections when they disclose information to the TPB.
1.43In 2019, the former Government announced an independent review of the TPB and the TAS Act tasked with considering the suitability and effectiveness of the legislative framework for the TPB. The Review of the Tax Practitioners Board - Final Report (TPB Review) was released on 27 November 2020 and included 28recommendations across eight broad reform areas.
1.44The TPB Review concluded that the inability of the TPB to receive information from an eligible whistleblower was an anomalous outcome. Schedule 2 responds to that finding and would amend the TA Act to extend whistleblower protections to eligible whistleblowers who make disclosures to the TPB, as well as other entities who may support or assist the whistleblower.
1.45Currently, whistleblower protections also apply when individuals make a disclosure to a legal practitioner for the purposes of obtaining legal advice or representation about disclosures. Schedule 2 would extend these protections to disclosures made to a medical practitioner, psychologist or an entity prescribed in the Tax Agent Services Regulations 2022 (TAS Regulations).
1.46Schedule 2 would also reverse the burden of proof for certain claims of protection under Part IVD of the TA Act, to better align with public interest disclosures. This would apply in a similar manner to parts of the Public Interest Disclosure Act 2013 (PID Act), by encouraging employees, former employees, and others to disclose wrongdoing by Commonwealth public sector officials without fear of detriment.
Schedule 3—PwC response—Tax Practitioners Board reform
1.47Tax practitioners in Australia are regulated by the TPB, which is established under the TAS Act and the TAS Regulations. The object of the TAS Act is to ensure that tax agent services are provided to the public in accordance with appropriate standards of professional and ethical conduct.
1.48That said, there is currently a lack of public transparency regarding the publication of material by the TPB on the misconduct of tax practitioners. Schedule 3 aims to enhance public confidence in the regulation of the tax profession by implementing the second tranche of amendments arising from the TPB Review.
1.49Schedule 3 would implement amendments to improve the TPB Register (the register) and boost the TPB’s investigation powers. The amendments would:
increase the information published on the register;
change how time limits are prescribed for certain information to remain on the register;
extend the timeframe that the TPB has to conduct an investigation; and
better target the TPB’s delegation powers.
1.50Schedule 3 would make amendments to enable the TAS Act and TAS Regulations to require additional information about tax practitioners and entities to be published on the register. This additional information could include, for example, the results of investigations into tax practitioner conduct.
1.51The TAS Regulations would also be able to prescribe circumstances for unregistered entities to be included on the register. This is intended to address a loophole whereby tax practitioners who were found to breach the TAS Act could avoid being included on the register if their registration lapsed during an investigation.
1.52The TPB could remake decisions where the TPB decided to take no further action between 1 July 2022 and commencement of the bill because the registration of an entity being investigated lapsed. The TPB would have six months from commencement of the bill to remake the decision and publish relevant information on the register in accordance with the TAS Regulations.
1.53This decision would be valid despite any time limits for decision-making imposed by the TAS Act, but the TPB must follow the notification process outlined in the TAS Act, and the decision would be subject to merits review by the Administrative Appeals Tribunal.
1.54Currently, under the TAS Act, details of unregistered tax practitioners are to remain on the register for 12 months. Schedule 3 would change this by enabling the TAS Regulations to specify the period of time for which details are to remain on the register.
1.55It is appropriate for the TAS Regulations to specify this information, as there are a range of circumstances in which an entity may be subject to a finding of misconduct, and a range of responses the TPB may take in response to breaches. Specification in the TAS Regulations would allow the publication period and the level of detail provided on the register to be proportionate to the significance or seriousness of the misconduct.
Timeframes and publication of Tax Practitioner Board investigations
1.56Schedule 3 would also extend the default timeframe for the TPB to conduct investigations from six months to 24 months with the possibility of extension. This extension addresses findings that the current six-month period is insufficient for the TPB to conduct detailed reviews of complex cases.
1.57This extension would apply to investigations which commence on or after the day the bill commences, and to ongoing investigations where a decision is yet to be made. Certain other investigations are also automatically extended to 24months.
1.58Additionally, the bill would allow the TPB to publish specified information about an entity, such as the findings of an investigation, on the register. The power to publish this information may be instead of or in addition to other administrative sanctions or civil penalties. This power has been introduced because of scenarios in which there is a breach of the TAS Act, but pursuing sanctions is not a reasonable course of action.
1.59However, where the TPB decides to publish findings of an investigation which include a finding of misconduct, the relevant information about the contravening entity must be included on the register.
Schedule 4—PwC response—Information sharing
1.60The PwC tax leaks scandal has highlighted that the current secrecy provisions have prevented effective communication, collaboration, and coordination within and among government ministers and agencies in responding to misconduct by large consulting, accounting, and auditing firms who engage with the Commonwealth.
Enabling the sharing of information relating to misconduct
1.61Under current laws the ATO and TPB are prohibited from sharing protected information relating to misconduct with the Treasury.
1.62Schedule 4 would make amendments to assist the Commonwealth to identify and pursue suspected breaches of confidence and to deter future misconduct by intermediaries engaging with the Commonwealth. It would allow taxation officers and TPB officials to share protected information with the Secretary of the Treasury where:
there is a breach or suspected breach of an obligation of confidence by an entity against the Commonwealth or a Commonwealth entity;
the obligation arose in connection with the entity providing advice or services to a Commonwealth entity either as engaged by the Commonwealth or as representing a taxpayer;
the sharing of protected information is for the purpose of enabling or assisting in any measure or action directed at dealing with the breach or suspected breach.
1.63Obligations of confidence may be imposed by contract, such as a non-disclosure agreement, or from other sources which would make sharing the information a breach of confidence. The advice or service provided by the entity which breached, or was suspected to have breached, the obligation need not have been provided for a fee.
1.64The Treasury’s options for investigating a potential breach and responding to a breach are not intended to be limited. The Treasury may develop measures that are broader than directly addressing the breach.
Enabling Treasury officials to share information relating to misconduct
1.65Currently, under the TA Act and TAS Act, someone who is neither a taxation officer nor a TPB official is prohibited from disclosing protected information, subject to limited exceptions.
1.66The bill would introduce new exceptions to the TA Act and TAS Act to enable disclosure of protected information obtained by the Treasury for the purpose of the Treasury developing and implementing an appropriate response on behalf of the Commonwealth in response to a suspected breach of confidence.
1.67These new exceptions are intended to ensure that Treasury officials may advise relevant Ministers about a breach or suspected breach of an obligation of confidence owed to the Commonwealth or a Commonwealth entity. Existing limits on these types of disclosures will be extended to apply to Treasury officials making such disclosures.
Enabling disclosures to professional disciplinary bodies
1.68Prior to this bill, there was no general principle that would allow disclosure to relevant professional disciplinary bodies simply because the ATO or TPB had evidence of legal or ethical misconduct by members of the relevant body. This inhibits the proper operation of self-regulatory models that exist in many professions.
1.69Schedule 4 would enable taxation officers and TPB officials to disclose protected information relating to acts or omissions by a person to professional disciplinary bodies prescribed in the regulations, where the officer or official reasonably suspects such acts or omissions may constitute a breach of the body’s code of conduct or professional standards.
1.70Prior to prescribing any bodies, consideration will be given to whether the body has appropriate processes and safeguards in place for appropriately managing the protected information.
Privacy for taxpayers
1.71The amendments would ensure that disclosures do not include information of taxpayers not involved in any wrongdoing, where the taxpayer is represented by an intermediary that is the focus of a disclosure. Secrecy offences exist under the TA Act and TAS Act which mean taxation officers and TPB officials are not able to disclose the details of entities other than the entity suspected of misconduct.
1.72Some exceptions to these secrecy offences already exist. The bill would introduce another exception to the requirement not to disclose a taxpayer’s information, which would apply where withholding this information would prevent action being taken against the intermediary.
1.73This exception would apply where the Commissioner or the TPB is satisfied that the inclusion of the information is necessary for either:
enabling or assisting in developing or implementing a measure or action directed at dealing with the breach or suspected breach, where the information is shared to the Treasury; or
enabling a prescribed disciplinary body to perform one or more of its functions in respect of the first entity, where the information is shared to a prescribed professional disciplinary body.
1.74These exceptions would reverse the burden of proof for the offence of disclosing protected information. A taxation officer would be required to show that a disclosure was necessary for one of the permitted purposes in order to show that a disclosure was not an offence. The Explanatory Memorandum explains that this is in accordance with the Guide to Framing Commonwealth Offences, because the matter may be peculiarly within the knowledge of the defendant, and it may be more difficult and costly for the prosecution to prove the matter.
Petroleum resource rent tax deductions cap
Schedule 5—Petroleum resource rent tax
1.75The PRRT is a federal, profits-based resource rent tax on petroleum and gas projects located offshore in Australian waters. The PRRT operates under the Petroleum Resource Rent Tax Assessment Act 1987 (PRRTA Act).
1.76The PRRT taxes the profits of a person in relation to a petroleum project in a year of tax. Taxable profit is determined as the amount by which assessable receipts exceed deductible expenditure and transferrable exploration expenditure.
1.77Currently, the PRRT taxes petroleum projects at 40 per cent of total profits. Deductions are available under section 38 of the PRRTA Act for ‘general project expenditure’ that allow project sponsors to recoup capital expenditure, including exploration, feasibility, and operational costs, from their taxable profits prior to the tax applying.
1.78In effect, under these arrangements PRRT is only paid when a project’s total taxable profits exceed total deductible expenditure. Modelling undertaken by the Treasury as part of the PRRT Review revealed that most eligible projects are not expected to pay any significant amount of PRRT until the 2030s.
1.79For example, in the 2020–21 financial year, only six PRRT projects out of a total of 33 PRRT projects paid any tax.
1.80Schedule 5 of the bill would amend the PRRTA Act to effectively cap the availability of deductible expenditure at 90 per cent of total PRRT assessable receipts. This would ensure that the 40 per cent PRRT tax rate would be paid on at least 10 per cent of the revenue coming from all eligible PRRT petroleum and gas projects. The changes would mean the offshore liquefied natural gas (LNG) industry pays more tax sooner.
1.81Schedule 5 partially implements the ‘Petroleum Resource Rent Tax – Government Response to the Review of the Petroleum Resource Rent Tax (PRRT) Gas Transfer Pricing arrangements’ measure announced in the 2023–24 Budget.
Context for PRRT amendments
1.82On 30 November 2016, the Turnbull Government announced that Michael Callaghan AM PSM would lead a review into the design and operation of the PRRT (the Callaghan Review).
1.83The Callaghan Review was released in April 2017 and raised concerns that the outcomes of the Gas Transfer Pricing arrangements were not returning an equitable share of the profits of offshore liquefied natural gas projects to the Australian people. The Callaghan Review made 12recommendations to update and improve the integrity, efficiency, and administration of the PRRT with a view to ensuring a greater tax benefit for Australians.
1.84On 2 November 2018, the former Government announced its final response to the Callaghan Review which chiefly included tasking the Treasury to undertake a review of the PRRT, which resulted in the Petroleum Resource Rent Tax: Review of Gas Transfer Pricing Arrangements Final Report (the Treasury PRRT Review).
1.85The Treasury PRRT Review was released in May 2023 and further highlighted the shortcomings of the PRRT as it applies to the LNG industry and made an additional 11 recommendations to update and improve the PRRT.
1.86There is a general sense, captured in both the Callaghan Review and the Treasury PRRT Review, that the PRRT in its current state is not fit-for-purpose and does not ensure a fair return on the exploitation of commonly-owned resources to the Australian people.
Consultation
PwC response
1.87The Treasury undertook a consultation process on exposure draft legislation for each of the four schedules relating to the PwC response between 20September 2023 and 4 October 2023.
1.88Published submissions received as part of the exposure draft legislation process are available on the Treasury’s consultation hub.
Petroleum resource rent tax
1.89The consultation process for the petroleum resource rent tax changes is outlined in the Treasury PRRT Review which was provided as an attachment to the EM.
1.90The first round of stakeholder engagements with industry participants was held in January 2019. In April 2020, the Review was paused and resources were diverted to the COVID-19 pandemic response. Consultation recommenced in December 2022. The review was provided to the Treasurer in May 2023.
1.91The review states that consultation was largely confidential, but included engagements with industry, independent industry analysts, and State and Territory Governments.
Commencement
1.92Schedules 1 to 3 would commence on the later of 1 July 2024, or the first day of the first quarter following the Royal Assent.
1.93Schedule 4 would commence on the day after the bill receives the Royal Assent.
1.94Schedule 5 would commence on the first day of the first quarter that occurs after the day the bill receives the Royal Assent.
Financial impact
1.95According to the EM, Schedule 1 is expected to have an unquantifiable but positive impact on receipts. Financial impacts are expected to first occur in 2024—25.
1.96Schedules 2 through 4 are not expected to have any financial impact.
1.97Schedule 5, in combination with other elements of the 2023—24 Budget measure ‘Petroleum Resource Rent Tax – Government Response to the Review of the PRRT Gas Transfer Pricing arrangements’, are estimated to increase receipts by $2.4 billion over the 4 years from 2023—24.
Legislative scrutiny
1.98In its Scrutiny Digest 15 of 2023, the Senate Standing Committee for the Scrutiny of Bills did not raise any concerns regarding the bill.
Human rights implications
1.99As discussed in the EM, the Statement of Compatibility with Human Rights argues that the bill is compatible with human rights and freedoms recognised in the international instruments listed in section 3 of the Human Rights (Parliamentary Scrutiny) Act 2011, and thus does not raise any human rights concerns.
1.100In its Report 13 of 2023, the Parliamentary Joint Committee on Human Rights reported that the bill did not raise any human rights concerns.
Regulatory impact
1.101The EM does not provide a Regulatory Impact Statement for Schedules 1 through 4 relating to the PwC response.
1.102The EM states that the Impact Analysis for Schedule 5 is contained in the Petroleum Resource Rent Tax: Review of Gas Transfer Pricing Arrangements Final Report.
Acknowledgements
1.103The committee thanks all those individuals and organisations who assisted with the inquiry, especially those who made written submissions and participated in the public hearing.
Conduct of the inquiry
1.104The committee agreed to open submissions until 9 February 2024. The committee wrote to a range of key stakeholder groups, organisations and individuals, drawing their attention to the inquiry and inviting them to make a written submission.
1.105The committee received 15 submissions, which are available on the committee's webpage and listed at Appendix 1.
1.106The committee held a public hearing in Canberra and via videoconference on 9April 2024. A list of witnesses can be found at Appendix 2.
1.107Details of the inquiry, including links to the bill and associated documents, are published on the committee's website.
Report structure
1.108This report contains three chapters.
1.109This chapter provides an overview of the purpose and provisions of the bill.
1.110Chapter 2 covers schedules 1 to 4 of the bill relating to the PwC response. It outlines key issues raised about these schedules in evidence and presents the committee's views and recommendation.
1.111Chapter 3 covers schedule 5 of the bill relating to the proposed reforms to the PRRT. It outlines key issues raised about this schedule of the bill in evidence and presents the committee's views and recommendation.