Many members of CA ANZ and CPA (the joint bodies) are involved with the not for profit (NFP) sector as advisors, auditors, employees and volunteers. The joint bodies are strong supporters of the NFP sector.

The Productivity Commission’s draft report into the future foundations of giving covers a wide range of issues. The joint submission discusses some, but not all, of the information requests and draft recommendations in the report.

Data about the NFP sector is sparse. The joint bodies suggest that the Productivity Commission look for opportunities to collate and publicise information already collected by various regulators to help support recommendations in its report.

The draft report contains two recommendations about tax that affect deductible gift recipients.

• Firstly, that the $2 threshold for tax deductions be removed – the joint bodies support this in principle but note that whether it will make a practical difference to the amount of giving will depend on the compliance approach of the Australian Taxation Office.
• Secondly, that the DGR system be reformed. In previous submissions the joint bodies have expressed support for further refinement of the DGR framework with the aim to both alleviate the administrative burden on NFPs and to strengthen the registration, reporting and regulatory environment. The joint bodies support in principle, the creation of a simpler, refocused DGR regime using the principles outlined in Recommendation 6.1 and the charity subtype classifications set out in the Australian Charities and Not-for-profits Commission Act 2012 (Cth) (ACNC Act). However, calls are made for the activities listed for proposed exclusion in the draft recommendation be subject to further consultation and research.

The draft report contains several regulatory recommendations as well. The joint bodies support the following draft recommendations:

• A more consistent and transparent approach for basic religious charities provided that it does not impose unnecessary duplicative obligations.
• Providing the ACNC with the ability to issue binding rulings. The joint bodies note that the ACNC would need more funding to fulfil this new role.
• Creation of a national charities regulator’s forum.
• Explicit consideration of the effects on volunteers when designing policies and programmes
• Enabling distributions from ancillary funds to be smoothed over three years.