Tax authority immunity in a digital tax administration world

Research output: Contribution to journalArticleResearchpeer-review


Tax authorities in developed common law countries such as the United States, Australia and Canada are increasingly moving to digitise and automate tax administration. The move is rapid and multi-faceted, extending to core functions including tax compliance and investigation activities. However, this increasing reliance on digitisation, automation and artificial intelligence raises fundamental questions concerning tax authority accountability and the ability of taxpayers to exercise their rights to take legal action in the event of defective tax administration. To date, these questions have garnered little attention in the evaluation of the merits, efficiencies and goals of the push to digitise and automate. This article considers these questions and posits that the answers indicate a need to rethink the key public policy principles underpinning the legal rules which govern the limits of tax authority susceptibility to taxpayer suit.

Original languageEnglish
Pages (from-to)402-440
Number of pages39
JournaleJournal of Tax Research
Issue number2
Publication statusPublished - 2020


  • artificial intelligence
  • public policy
  • tax administration

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