The Order uses three core legal concepts, all narrowly defined by the text of the instrument:

• Corresponding Commissioner: s 3(a) declares that the holders of the offices listed in Schedule 1 are "corresponding Commissioners" for the purposes of s 79A of the Taxation Administration Act 1997. Schedule 1 lists offices by jurisdiction (Australian Capital Territory, New South Wales, Northern Territory, Queensland, South Australia, Victoria, Western Australia) and specifies particular office titles (for example, "Commissioner for Australian Capital Territory Revenue", "Chief Commissioner of State Revenue", "Assistant Commissioner of Land Tax", and so on). The Order does not define the phrase "corresponding Commissioner" beyond declaring which offices are to be treated as such for the stated statutory purpose.

• Corresponding law: s 3(b) declares that the laws listed in Schedule 2 are "corresponding laws" for the purposes of s 79A. Schedule 2 enumerates particular State and Territory tax-related statutes (stamp acts, payroll tax acts, land tax acts, duties acts, taxation administration acts, and other revenue-related legislation) across the jurisdictions named in Schedule 1. The Order lists some Acts with full year citations and others by title alone where the year is not given.

• Purpose limitation: the Order repeatedly ties the declarations to a single external statutory provision. The operative clause is framed expressly "For the purposes of [section 79A of the] Taxation Administration Act 1997" (s 3). The Order therefore functions as an implementing or supplementary instrument to another piece of primary legislation; on its face it does not create substantive Commonwealth tax powers or reciprocal mechanisms, it supplies lists that are intended to be used by s 79A.

Two ancillary points in the instrument further structure its meaning:

• Commencement: the Order does not specify a fixed calendar date, it takes effect upon notification in the Gazette (s 2). The instrument records that notification occurred on 22 January 2003.

• Amendments: both Schedule 1 and Schedule 2 carry bracketed notes that they were amended by S.R. 2005, No. 74, applied 29 June 2005. Those bracketed notes are part of the text provided and indicate that the Schedules were altered by a later legislative instrument; the Order as printed includes the amendment notices adjacent to the Schedules.

The instrument’s scope is therefore definitional and declaratory. It is best understood as a list-making mechanism: it identifies the State and Territory offices and statutes that another statutory provision will treat as corresponding. The Order contains no standalone regulatory regime, no penalty provisions, nor any operational instructions for how correspondences are to be used.

The Order expressly targets a narrow set of institutional actors and legal instruments. The following categories of persons and entities are directly implicated by the text:

• Holders of listed offices (Schedule 1): the Order declares the holders of specific offices to be "corresponding Commissioners". Those offices are the state and territory revenue offices and certain deputy/assistant commissioner positions across jurisdictions. Examples include the Commissioner for Australian Capital Territory Revenue; Chief Commissioner of State Revenue (New South Wales); Commissioner of Taxes (Northern Territory); Commissioner of State Revenue and Assistant Commissioners for Land Tax and Tobacco Products Licensing (Queensland); Commissioner of State Taxation (South Australia); Commissioner of State Revenue (Victoria); Commissioner of State Revenue (Western Australia). The instrument therefore designates specific state/territory revenue office-holders to be treated as corresponding Commissioners for the statutory purpose identified.

• State and Territory statutes (Schedule 2): the Order declares particular Acts to be "corresponding laws". The lists encompass a wide set of revenue-related enactments in each jurisdiction: stamp duties, payroll tax, land tax, duties acts, taxation administration acts, debits tax acts, energy and fuel levy/subsidy statutes, tobacco licensing and related statutes, and miscellaneous revenue laws. Those statutes are the legal instruments that the Commonwealth provision (s 79A) will consider corresponding laws when applying its reciprocal or cooperative mechanisms.

• Department of Treasury and Finance: the printed instrument records that the Order is administered by the Department of Treasury and Finance. That identifies the Commonwealth administrative custodian or manager of the instrument as issued.

• Indirectly affected parties: while the Order does not itself create taxpayer obligations or rights, the mapping may have downstream effects on taxpayers and practitioners to the extent s 79A uses the declared correspondences to authorise cross-jurisdictional cooperation, information sharing, reciprocal enforcement, or recognition of officers. Any such downstream effect would ultimately impact state/territory revenue agencies, registered tax agents, accountants, lawyers, and taxpayers who interact with revenue administrations. The Order itself, however, does not spell out those consequences; it only supplies the lists s 79A will use.

Who does not get affected by the Order, as a matter of text, is also notable. The Order does not amend or repeal any of the listed State or Territory laws; it does not appoint individuals into office; it does not create Commonwealth-level tax liabilities; and it does not, on its face, impose any compliance costs or penalties on private persons. Its effect is limited to making the declared correspondences available for the referenced statutory purpose.

Because the Order lists offices precisely by title, it matters which official titles are included. For example, in Queensland the Order lists both the Commissioner of State Revenue and two Assistant Commissioners (Land Tax and Tobacco Products Licensing). The inclusion of particular assistant roles alongside primary commissioners shapes which office-holders will be treated as corresponding Commissioners under the external statutory rubric. That is a direct effect on those offices and on how external authorities may interact with them under s 79A.

The Order itself does not create novel duties, rights, powers, or offences for individuals or entities. Its operative content is declaratory: it declares which offices are corresponding Commissioners and which statutes are corresponding laws for the purpose identified in s 3. From the text the following are the key legal characteristics to be noted:

• No standalone duties or rights in the Order: neither s 1, s 2 nor s 3, nor the Schedules, impose obligations on taxpayers, require actions from the listed office-holders, or confer privileges directly on private parties. The Order is not framed as a regulatory code that imposes duties; rather it supplies lists that another statutory provision will reference.

• Delegated-listing function: the Order's key legal operation is to identify actors and instruments that will be treated as "corresponding" under s 79A. The mechanical legal consequence is that the named offices and statutes are to be used by the referenced provision. The Order does not explain the substantive content of being a "corresponding Commissioner" or a "corresponding law"; it simply declares which offices/acts fall within those labels for the referenced purpose.

• Administrative accountability: the Order indicates it is administered by the Department of Treasury and Finance (instrument footer). That identifies the Commonwealth administrative body responsible for custody and likely publication/record-keeping of the instrument. The Order does not, however, specify operational responsibilities for that department beyond administration.

• Effect of listed offices: by specifying particular office titles in Schedule 1, the Order ties the legal recognition under s 79A to those office-holders. This creates a predictable mapping so that any use of the term "corresponding Commissioner" in the context of s 79A can be resolved by reference to the Order. That predictability functions as a legal mechanism for identifying the counterpart official the Commonwealth will recognise in dealings that invoke s 79A. The Order does not, in itself, grant those office-holders additional powers; it makes them the counterparts for the statutory scheme referenced.

• Effect of listed laws: similarly, by enumerating statutes in Schedule 2, the Order gives a concrete list of which State and Territory revenue statutes will be treated as "corresponding laws" under s 79A. Where s 79A requires that a law be a "corresponding law" to have certain reciprocal effect, the Order supplies the list to trigger that effect. The Order does not alter the substantive content of those State/Territory Acts.

Practically, the Order acts as a legal cross-reference tool: its primary function is to remove ambiguity about which offices and statutes are to be covered when s 79A is invoked. It therefore contributes to legal certainty in respect of identification of counterpart offices and instruments, not by creating rights or duties directly, but by resolving labels and mappings that will matter under the referenced statutory provision.

The Order contains no penalty provisions, enforcement mechanisms, or administrative sanctions. Neither the body of the Order nor the Schedules create offences, fines, or compliance regimes. The text is purely declaratory and list-based. The following points flow from the instrument's content:

• No penalties in the instrument: there is no clause that prescribes penalties, monetary obligations, or enforcement steps for failure to comply. The instrument does not create an inspection regime, audit powers, or review processes.

• Enforcement, if any, would derive from other law: because the Order operates "for the purposes of section 79A of the Taxation Administration Act 1997" (s 3), any enforcement tied to the practical consequences of being a "corresponding Commissioner" or a "corresponding law" will depend on the substantive provisions of s 79A and other operative provisions of the Taxation Administration Act 1997 or the relevant State/Territory statutes. The Order itself does not contain or authorise enforcement; it only supplies the lists s 79A will reference.

• Administrative effect on recognition and cooperation: the only enforcement-like function the Order performs is to identify which State/Territory officers and statutes are to be regarded as correspondents. That identification can influence which bodies are engaged in cooperative enforcement actions if s 79A or other legislation uses the declared correspondences as a trigger. The instrument does not itself create an enforcement power.

• Publication and notice: the Order’s commencement depends on Gazette notification (s 2). The instrument records its Gazette notification date of 22 January 2003. Publication in the Gazette functions as formal notice and is the procedural step that gives the Order legal effect under its own terms; but the Order sets no further administrative sanctions for non-publication or defective publication.

In short, this Order contains no independent enforcement apparatus. Any penalties or compulsory mechanisms relevant to actions taken by "corresponding Commissioners" or under "corresponding laws" will have to be located in the Taxation Administration Act 1997 (including s 79A) or the State/Territory statutes listed in Schedule 2. The Order itself is a recognition instrument rather than an enforcement instrument.

The instrument is expressly constructed to interact with at least two legal layers: the Taxation Administration Act 1997 (specifically s 79A) and the State and Territory statutes listed in Schedule 2. The text establishes a set of mappings that another statute will consume; the following interactions are explicit in the instrument:

• Primary statutory cross-reference: s 3 frames the entire Order as being "for the purposes of [section 79A of the] Taxation Administration Act 1997". That is the only direct statutory cross-reference in the instrument. The Order therefore functions as a subordinate instrument that supplies the necessary lists for s 79A to operate. The instrument does not reproduce or restate the content of s 79A, so to understand the full legal effect of the declared correspondences a reader must consult s 79A itself.

• Listing of corresponding laws: Schedule 2 enumerates a set of State and Territory Acts , for example, "Stamp Duties Act 1920" (NSW), "Pay-roll Tax Act 1971" (NSW), "Land Tax Act 1956" (NSW), and similar statutes across other jurisdictions. By declaring these enactments to be "corresponding laws" for the purposes of s 79A, the Order establishes a legal link between Commonwealth administrative arrangements and those State/Territory statutory schemes. The instrument does not amend or modify those Acts; it recognises them as the relevant counterparts.

• Identifying corresponding offices: Schedule 1 lists the office-holders who are to be regarded as corresponding Commissioners. That list directly ties specific State/Territory revenue offices and certain assistant commissioner roles to the term "corresponding Commissioner". That identification will matter where Commonwealth law (via s 79A or related provisions) requires recognition of a corresponding State/Territory official in cooperative procedures.

• Secondary legislative context: the footer notes that the Order is displayed and numbered in accordance with the Rules Publication Act 1953 and that it was notified in the Gazette on 22 January 2003; it is also administered by the Department of Treasury and Finance. Those procedural references situate the Order in the Commonwealth subordinate legislation framework but do not alter its substantive mapping function.

• Amendment interplay: bracketed notes indicate that Schedule 1 and Schedule 2 were amended by S.R. 2005 No. 74 (applied 29 June 2005). That shows the Order is susceptible to amendment by later subordinate instruments, and that the list of corresponding Commissioners and corresponding laws can be updated by such amendments. Any change in the Schedules will therefore alter the set of offices and laws that s 79A will treat as correspondent.

What the Order does not do, based on its text:

• It does not purport to alter State/Territory legislation or to modify the powers of State/Territory officers in their home jurisdictions.
• It does not create a new framework of cooperative powers itself; it supplies definitional input to another statutory framework.
• It does not reconcile differences among the listed State/Territory statutes; it simply lists them.

Therefore, the Order’s interaction is one of legal recognition and cross-reference: it tells the Commonwealth (and the public) which State/Territory offices and Acts will be the counterparts in the statutory mechanism created elsewhere in Commonwealth law. The precise legal consequences of those correspondences must be located in the cross-referenced provision (s 79A) and the listed State/Territory statutes.

The instrument as printed contains internal editorial notes showing subsequent amendments to its Schedules. The text records the following amendment-related facts:

• Schedules amended by S.R. 2005 No. 74: both Schedule 1 and Schedule 2 bear bracketed annotations stating "[Schedule 1 Amended by S.R. 2005, No. 74, Applied:29 Jun 2005]" and similarly for Schedule 2. Those annotations are part of the printed version of the Order and indicate that a later subordinate legislative instrument (Statutory Rule 2005 No. 74) made amendments that applied on 29 June 2005.

• No other amendment dates are recorded in the text provided. The instrument’s body contains no other amendment history entries or repeal clauses. The only commencement note is that the Order takes effect on notification in the Gazette (s 2), with the instrument indicating it was notified on 22 January 2003.

• Display and numbering statement: the Order includes the statement "Displayed and numbered in accordance with the Rules Publication Act 1953." That procedural note indicates compliance with the statutory regime for publication of rules and subordinate instruments, but it does not list subsequent changes beyond the S.R. 2005 annotation.

• Administrative continuity: the instrument lists the Department of Treasury and Finance as the administering department. There is no express amendment power within the text of the Order, but the presence of later S.R. amendments demonstrates that the Schedules are maintained via subsequent subordinate instruments.

Readers relying on this Order should treat the Schedules as potentially updated by later Statutory Rules or subordinate instruments, and note that the printed instrument includes an explicit amendment by S.R. 2005 No. 74. The Order as supplied does not list any earlier or later changes; to confirm the current state of the Schedules a practitioner must check subsequent instruments or the consolidated legislative database for further amendments beyond S.R. 2005 No. 74.

The text supplied contains no litigation history, judicial decisions, or references to litigation concerning the Order. The instrument itself does not cite any cases, and there are no notes within the Order indicating that it has been the subject of judicial review, declaratory relief, or other litigation.

Given the instrument’s declaratory nature , it supplies lists of offices and statutes for the purposes of an external provision (s 79A) , the absence of litigation references in the Order is unsurprising. The Order does not create rights, duties, or penalties directly; therefore disputes that might involve the Order would likely arise incidentally in litigation that concerns the application of s 79A or the State/Territory statutes listed in Schedule 2.

Because the source text provides no cases, decisions, or judicial commentary, the Order’s litigation history is nil in the text. Practitioners seeking judicial interpretations of the operative effect of "corresponding Commissioner" or "corresponding law" as used in s 79A will need to consult the case law addressing s 79A and those statutory concepts; nothing about such case law is contained in this instrument.

If a reader requires whether any subsequent judicial decisions address the lists in Schedules 1 and 2 or contest the effect of this Order, those materials fall outside the content of the Order itself and must be obtained from case law databases or authoritative consolidated versions of the Taxation Administration Act 1997 and its subordinate instruments.

The instrument’s brevity and list-based form create several practical particulars that can trap unwary users. The following "gotchas" are grounded in the text and formatting of the Order:

• The Order supplies lists but not definitions: the Order declares offices and laws are "corresponding" but does not define what that status entails. The consequence is that the import of being a "corresponding Commissioner" or a "corresponding law" is determined by the external provision (s 79A) and not by this Order. Do not assume substantive powers or duties flow directly from being listed here; the Order does not say so.

• Reliance on s 79A is essential: every operative declaration is expressly for the purposes of s 79A. If the legal effect of a list-item is in dispute, the resolution depends on s 79A and any other connected provisions, not on the Order itself. Lawyers must consult the referenced primary legislation to understand the practical effect.

• Title specificity matters: Schedule 1 lists certain subordinate or assistant office titles in some jurisdictions. For example, Queensland lists "Assistant Commissioner of Land Tax" and "Assistant Commissioner of Tobacco Products Licensing" alongside the "Commissioner of State Revenue". If a practitioner is dealing with recognition or correspondence issues, these specific titles determine which office-holders are treated as corresponding Commissioners. Omission or variation in title might matter; the Order is specific and not general.

• Variation of statute citations: Schedule 2 mixes fully cited Acts (with years) and entries without a year (notably some Northern Territory entries). That may generate ambiguity about the precise legislative instrument intended in cases where multiple Acts have similar names or have been re-enacted. The Order’s text, as printed, is the controlling listing; if there is ambiguity practitioners must cross-check versions of the state statutes.

• Amendments recorded within the Order: bracketed notes show S.R. 2005 No. 74 amended the Schedules. However, the Order as provided does not show the pre-amendment versions or the text of the amending instrument. To confirm whether a listed office or law remains current, one must check the amending instrument and any further amendments. The bracketed note is a pointer, not a substitute for checking the amending instrument.

• No substantive change mechanism included: the Order contains no mechanism for automatic updating if State/Territory statutes are renamed or offices reorganised. Where a State changes the title of an office or consolidates an Act under a new name, the Order must be amended by later subordinate instrument to reflect that change. Until amended, the Order will list the historic titles as the legally declared correspondents.

• Administrative custody and notice: the Order takes effect on Gazette notification (s 2). If the Gazette notice is defective or delayed, questions of commencement could arise. The instrument records the Gazette notification date of 22 January 2003; reliance on the Order should confirm that notice was properly published.

• Limited geographic scope: Schedule 1 lists only mainland states and territories' revenue offices. Entities or offices not captured in Schedule 1 are not declared corresponding Commissioners; do not infer coverage beyond the listed offices.

These practical points mean that practitioners must treat the Order as an enabling list rather than a source of substantive powers. Confirm current Schedules against later amending instruments, check exact office titles and statutory citations when advising clients, and consult s 79A to understand how the correspondences are used.

Because the Order does not impose duties or penalties, "compliance" here means two things: (a) administrative compliance by public bodies responsible for managing the listed correspondences and (b) how practitioners and affected parties should act to ensure legal certainty when the declared correspondences matter under s 79A. The Order’s text suggests the following concrete steps:

For administering agencies and listed offices

• Treat the Gazette notification as the commencement point: the Order takes effect on notification in the Gazette (s 2) and records notification on 22 January 2003. Administrative records should keep the Gazette notice and any amendment instruments (e.g. S.R. 2005 No. 74) together with the Order.

• Acknowledge the Departmental custodian: the Order is administered by the Department of Treasury and Finance. That department should maintain authoritative copies, consolidation of amendments, and a public-facing record so third parties can confirm which offices and laws have been declared.

• Monitor and update Schedules via subordinate instruments: the Schedules have been amended before (S.R. 2005 No. 74). If State/Territory office titles or relevant statutes are renamed or repealed, the Commonwealth should issue amending statutory rules to keep the lists current. The Order itself contains no automatic update mechanism.

• Ensure office-holders know their declared status: listed office-holders (including assistant commissioners listed in Schedule 1) should be notified internally that their office is declared a corresponding Commissioner for the purposes of s 79A. That will help avoid confusion when counterparties seek to treat them as such in cooperative or reciprocal arrangements under s 79A.

For practitioners advising taxpayers, agents, or revenue offices

• Use the Order as an index only: when a matter invokes "corresponding Commissioner" or "corresponding law" under s 79A, consult this Order to identify which Office or statute is intended. Do not rely on the Order alone to determine substantive powers; it defines counterparts, not the powers attached to them.

• Cross-check State/Territory statute versions: Schedule 2 lists many State/Territory Acts. Confirm the current text and title of each listed Act in the relevant jurisdiction; some entries in the Order are cited without years or with historical titles. For precision in advice, identify the contemporary enactment that corresponds to each Schedule 2 item.

• Verify amendments: bracketed notes show amendments by S.R. 2005 No. 74. Before relying on the Order, check whether subsequent amending instruments have further altered the Schedules. The Order as printed is not necessarily the final consolidated source without checking later SRs or consolidated instrument databases.

• Where operational cooperation is sought, start with s 79A: the Order’s declarations are for the purposes of s 79A. Any request to recognise a state official, to share information, or to take reciprocal action should be grounded in the operative provisions of s 79A and the relevant State/Territory Acts listed in Schedule 2. Advice should consider the substantive requirements in those statutes and not rely on the Order for procedural or substantive legitimacy.

Practical checklist (based solely on the Order’s text):

1. Keep a certified copy of the Order and the Gazette notice dated 22 January 2003.
2. Maintain a file of amending Statutory Rules, starting with S.R. 2005 No. 74 (applied 29 June 2005), and update the Schedules accordingly.
3. For each listed office in Schedule 1, maintain a current contact point and confirm the exact office title in the relevant State/Territory administration.
4. For each listed Act in Schedule 2, map the Schedule entry to the current statutory citation and version in the relevant jurisdiction.
5. When relying on correspondences in operative matters, cross-reference s 79A of the Taxation Administration Act 1997 for substantive authority.

Following these steps will ensure that administrative use of the Order’s lists is accurate and that practitioners do not mistake the Order’s declaratory lists for substantive sources of power or compliance obligations.