It is obviously a sensitive issue with Customs, whose CIO, Murray Harrison, contacted Borland when it was understood that Toomey was going to use the case as an example in his presentation. 'He hasn't worked directly for Customs,' Harrison said.

Toomey is raising questions in advance of massive changes planned by the Australian Tax Office, which plans to change its whole system this year in the four days between Christmas and New Year. 'If they can't do it in the four days, they will have to wait for the same window the following year. They should be able to do it incrementally.'