A citation on an answer, whether it comes from AI software, a research tool or a colleague's file note, makes a promise: that the answer rests on something you can open and read. At Toby we treat a citation as a set of checks the reader should be able to run in a few minutes, without searching.

It names the passage, not only the document

A citation that stops at the name of an Act, or at a publisher's home page, leaves you to hunt for the part that matters. The citation should name the section, subsection, paragraph or clause, so you land where the answer says it came from.

ATO rulings make this possible. Their paragraphs are numbered, and TR 2006/10, the ATO's ruling on public rulings, refers to its own paragraphs by number throughout. It also shows why the exact passage matters. A TR series ruling "contains a section labelled as a public ruling, and usually also contains explanatory material which does not form part of the binding public ruling". Two citations to the same ruling can point at material with a different standing, depending on which paragraphs they name.

It points at the version for your period

The law changes, and its publishers keep the versions. The Federal Register of Legislation explains in its FAQ that "Searching for a title ID will take you to the text page of the latest version of the title. Searching for a compilation ID will take you to a particular version of a title." It adds that "a superseded version always has the start date of the compilation in the URL."

A link to an Act's title page therefore opens today's version, whatever period the question was about. For a past quarter or an earlier year, the citation should name the compilation, or link to the version that applied then. Rulings change too: the ATO's page for TR 2006/10 notes that it "incorporates revisions made since original publication" and links to its history. We covered the dates behind an answer in why every AI answer needs a date on it.

The words there support the answer

Opening the source is half the check. The other half is reading the passage and asking whether it says what the answer says. A citation can be genuine and still fail to support the claim attached to it. The passage may deal with a different case, or carry an exception the answer left out.

Read the passage with the text around it. TR 2006/10 gives the example of a person who used a law companion ruling inappropriately, "choosing to rely on a single sentence in isolation rather than reading the law companion ruling as a whole", and says the ruling's protection did not apply to her. One quoted sentence in an answer deserves the same care.

This matters more when the answer comes from software that writes fluent text. The OAIC's guidance on commercially available AI products warns that the predictive nature of generative AI models "can lead to outputs that are inaccurate but appear credible". Its tips on accuracy suggest human oversight processes "which treat the outputs as statistically informed guesses". Until you have opened it, a citation inside a confident paragraph is part of that output.

You can stand behind it later

For a practitioner, checking the source is part of the work. Under competence, the Tax Practitioners Board's Code of Professional Conduct includes: "You must take reasonable care to ensure that taxation laws are applied correctly to the circumstances in relation to which you are providing advice to a client." A citation you have opened and read can go in your file note. One you have not opened is someone else's claim, and how a provision applies to a particular client remains a question for you or your own adviser.

What to check, in order

  1. Does the citation name a passage, such as a section, paragraph or clause, or only a document?
  2. Does the link open that passage at its publisher, rather than a summary or a copy?
  3. Is it the version that applied for the period the question is about?
  4. Do the words there say what the answer says, read with the text around them?
  5. Is it the binding part of the document, or explanatory or general material?

If an answer fails the first two, ask again and ask for the passage. If it fails the last three, the answer itself needs another look.

How we check citations at Toby

At Toby we hold the sources we cite in the form their publishers issued them. Our FAQ says documents are "held as published, so a citation points at the provision as it stood rather than a paraphrase", and that "The source is cited and linked, so you can read the provision or the published rate yourself." The same page says that if you ask as at a date, Toby answers on the law in force then where it holds the source for that date, naming the compilation, the version of the Act in force at the time, or the rate table it used. Where it does not hold the source, it "says so rather than filling the gap". Each answer carries the source and the provision, so the provision can be reread as it stood when a file note is reviewed later. Run the same five checks on our answers.

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Related reading

For the figure, the working and the date that sit beside a citation, see how to read a compliance answer.

Sources

  1. Federal Register of Legislation, Frequently Asked Questions. Supports the points on title IDs opening the latest version, compilation IDs opening a particular version, and the start date in a superseded version's URL.
  2. Australian Taxation Office, Taxation Ruling TR 2006/10, Public rulings. Supports the points on the binding section and explanatory material in a TR series ruling, reading a ruling as a whole, and the ruling's revision history.
  3. Office of the Australian Information Commissioner, Guidance on privacy and the use of commercially available AI products. Supports the points on outputs that are inaccurate but appear credible, and on treating outputs as statistically informed guesses.
  4. Tax Practitioners Board, Code of Professional Conduct. Supports the quoted reasonable care obligation under competence.