Submission on GST assurance for Australia’s Top 100 taxpayers
CA ANZ supports ATO’s proposed changes and calls for inclusive, practical guidance.
In Brief
- CA ANZ backs four-year GST check-ins for high-assurance taxpayers
- Input taxed and insurance taxpayers should be eligible to opt in
- Clearer guidance needed on tax control testing and system changes
Chartered Accountants Australia and New Zealand (CA ANZ) has responded positively to the Australian Taxation Office’s (ATO) proposed changes to the Top 100 GST program, following the introduction of the Supplementary Annual GST Return (SAGR). The changes aim to reduce compliance burdens and improve collaboration with taxpayers who demonstrate strong tax governance.
CA ANZ supports the move to four-yearly GST check-ins for high-assurance taxpayers, describing it as a step toward a more efficient and tailored compliance environment.
Key Points from the Submission
Inclusion of Input Taxed Reporters
CA ANZ recommends allowing input taxed reporters—particularly in financial services—to opt into the revised program. Many have achieved high assurance without using the GST analytical tool (GAT), and their exclusion may overlook their strong compliance efforts.
Consideration for Insurance Taxpayers
Due to the complexity of applying the GAT in the insurance sector, CA ANZ suggests exploring modified approaches or opt-in alternatives to ensure these taxpayers can benefit from reduced ATO scrutiny.
Guidance on Tax Control Testing
With greater reliance on independent tax control testing, CA ANZ calls for clearer guidance on ATO expectations. This includes how testing outcomes should be communicated and whether reports must be submitted with the SAGR or made available during check-ins.
Defining Significant Business or System Changes
CA ANZ urges the ATO to define what constitutes a “significant business or system change.” Clear parameters will help large organisations plan effectively and avoid unnecessary tailored reviews.
Clarifying Material Tax Risks and Review Interactions
The submission also requests more detailed guidance on material tax risks and how the revised program will interact with special GST reviews, helping taxpayers understand their ongoing obligations.
CA ANZ welcomes further engagement with the ATO to ensure the success of the revised GST program and maintain high levels of assurance among Australia’s largest taxpayers.
