Chartered Accountants Australia and New Zealand (CA ANZ) has welcomed the Board of Taxation’s efforts to modernise the Voluntary Tax Transparency Code (VTTC), aligning it with the global tax transparency standard GRI 207: Tax 2019 and Australia’s new public country-by-country (CBC) reporting regime. 

CA ANZ believes further refinements are necessary to ensure the VTTC remains practical, proportionate, and appropriately harmonised with Australia’s evolving tax transparency landscape. In the submission we make the following recommendations:

• to encourage medium entities to adopt the VTTC, Board may want to consider reducing the disclosures required for these entities
• the AASB guidance in the Draft Appendix should be finalised by the AASB before the release by the Board of the finalised redesigned VTTC
• to be more practical, we recommend that the reconciliation to Australian Taxation Office (ATO) corporate tax transparency disclosures be reclassified as an optional element rather than a minimum standard, allowing flexibility based on timing and relevance
• to streamline disclosures of subsidiaries in a consolidated group, where a non-public CBC reporter prepares a consolidated entity disclosure statement (CEDS), the reporter should be able to provide a link to the CEDS instead of providing a list of all the material subsidiaries in the group
• to boost participation, the ATO could enhance its VTTC webpages with more compelling messaging on the benefits of tax transparency.

In light of the Board’s work towards aligning the VTTC with other mandatory tax transparency requirements, CA ANZ is of the view that entities included in the public CBC reporting regime should be excluded from the ATO corporate tax transparency disclosures to reduce the red tape burden. Given the quality of the information provided under the public CBC reporting regime, the purpose for publishing the ATO corporate tax transparency data in respect of those entities is redundant and the differences in numbers provided only causes confusion for users.