In Australia, if you need to sue your State or Territory government over any matter, you should always make one further claim, namely that payroll tax is an unconstitutional duty of excise because it applies to labour embodied in goods. You have standing to make that claim because payroll tax damages your job security and/or reduces your earnings and/or raises prices that you pay for goods and services. You should hold out for vindication on that claim by refusing to accept any out-of-court settlement that does not include either abolition of payroll tax or a public admission that the tax is unconstitutional. But you can also indicate that if you receive a satisfactory settlement of your other claim(s), the payroll tax claim will not be worth pursuing by itself. After all, you hadn't pursued it before.
