摘要:It has taken just over ten years since the introduction of the goods and services tax (GST), but we are finally beginning to see a critical mass of GST cases work their way through the legal system. To date, many discussions around managing GST litigation have centred on the merits of declaratory relief versus taxation review and appeal proceedings brought under Part IVC of the Taxation Administration Act 1953 (Cth) (TAA). However, just as we have become familiar with that aspect of GST litigation, the Government is threatening to change the landscape yet again with the introduction of self assessment. At the same time, Federal Court litigation more broadly is changing. Not only has the Civil Dispute Resolution Act 2011 (Cth) commenced, but the Federal Court Rules have recently been rewritten.2