The Tax Office's Compliance Program

A speech by Jennie Granger, Second Commissioner, Australian Taxation Office to the Macquarie Bank’s Accountants Practice Management Day on 14 May 2004.

Introduction

Good morning and thank you to the Macquarie Bank for inviting me to talk to you about the work of the Tax Office today. I’m always pleased to have an opportunity to talk directly with colleagues in the tax industry.

As you know, tax agents play an essential role in helping to maintain the integrity of the tax system, so today is a good opportunity to provide you with information on our assessment of the health of the tax system, and our compliance strategies to address key risks and their results. Hopefully it will provide the right context for you, as well as information you can use, to assist your clients in managing their compliance with tax law.

Today I will give you an update on the Tax Office’s Compliance Program. I will also briefly outline some key areas of focus for next year, most of which were reflected in the Federal Budget.

In the post tax reform environment Commissioner Michael Carmody set a course for change in the Tax Office that he believed was essential to modernise our administration. He established a Change Program that is being designed with the community to transform our interactions in a way that makes it easier, cheaper and more personalised to deal with us. And secondly he announced we would begin rebalancing our compliance strategies, increasing our audit activities to balance our help and education approach that was very heavily emphasised during reform.

Twenty months ago two new Second Commissioners were appointed to complement Second Commissioner Mike D’Ascenzo, our Chief Tax Counsel. One was our Chief Operating Officer, Greg Farr - who has responsibility for delivering on major changes needed to deliver the Commissioner’s Easier, Cheaper, More Personalised commitments - and myself. I was appointed as Second Commissioner, Compliance. I have responsibility for delivering an integrated compliance program across the entire community and across all revenue products we administer. These products are income tax – including Pay as You Go and Fringe Benefits tax – Capital Gains Tax, GST, Excise and Superannuation.

Michael Carmody made it a key objective that the program be developed in a transparent way, so that the community could clearly understand the risks we are seeing, the strategies we are using to address those risks, and how effective we are in doing so. In what we believe is a world first in tax administration, the first program was published in 2002. We decided to open up our Compliance Program because we wanted to:

enhance confidence at the broad community level by improving the transparency of our program, allowing the community to see if it is balanced, appropriate and a cost effective program; and
at the individual level, alert people to where they may be exposed to a compliance risk and what they can expect from us.

Just to make life interesting, when I initially took on this challenge, we had just received additional funding from the Government and we were in the process of significantly enhancing our capability, including recruiting and skilling an extra thousand people. Needless to say, it’s been an exciting and challenging time.

Preparing for this speech has provided me with a good opportunity to share our reflections on our progression of the Compliance Program. We have marked our move beyond the implementation phase of the new tax system with increased openness and accountability. In August we will publish the third edition of the Compliance Program. It will again include the results of the previous program.

We are also publishing special focus booklets on areas of particular interest, such as Tax compliance and large business. This took our approach to using communications to positively influence compliance behaviour a step further. The next in the series was an area of significant community interest, Tax havens and tax administration.

In these booklets we go into greater depth on the risks we are concerned about and provide checklists for taxpayers and practitioners so that they are alerted to the characteristics we are concerned about and know what we will be focusing on.

Importantly, publishing our Compliance Program has helped us articulate much more clearly the characteristics of the various segments of the community with which we deal, the risks we are most concerned about and why, and what we are doing about them.

Today I’d like to share some of our assessment with you. I will also give you a brief insight into some changes in key focus areas in the coming financial year.

Background on the compliance program

Approximately 13 000 people, over half of the Tax Office’s staff, work in a compliance-related area involving a budget of $1.1 billion.

In shaping the Compliance Program it was fundamental to supporting our system of self-assessment that taxpayers have sufficient confidence that the Tax Office would provide them with the information they need. It was also critical we have an effective verification program to detect and address non-compliance. That is, the program must be an appropriately balanced mix of education, help and verification. They must also have confidence that we will act fairly and treat taxpayers according to their individual circumstances in all aspects of the program.

So in addressing tax compliance risks we employ a whole range of compliance activities across a spectrum, from advice and support to active compliance, which includes our verification and debt and lodgement activities.

To give you some sense of the scale of our help-focused activities, we have about 4350 staff providing advice and assistance, including marketing and education. This includes support to taxpayers and the community through targeted publications, answering nearly 12 million phone calls and providing 15,000 private binding rulings in 2002/03.

Our enforcement efforts aim to prevent, deter and detect non-compliant behaviour. About 5000 staff are devoted primarily to verification activities which, for 2002-03, yielded $3.3 billion in direct collections. A further 3000 are involved in debt and lodgement activity.

Compliance program achievements to date

We touch the lives of almost every single Australian at some point. To ensure we target our compliance efforts in the right place at the right time, we have segmented our approach to five “markets” in the community. These are:

large businesses - enterprises with a turnover of more than $100 million, and high wealth individuals;
small to medium businesses – enterprises with a turnover between $2 million and $100 million;
micro businesses – enterprises with a turnover of less than $2 milion;
individual taxpayers; and
government and not-for-profit entities.

Our compliance strategies and approaches are differentiated between markets. Let me take you through some of our analysis of market characteristics and our activities.

Large business segment

There are around 1400 large business groups, and 650 high wealth individuals with 14,000 associated entities. This segment also includes around 460 superannuation funds, which are required to comply with income tax and superannuation obligations.

Some estimates indicate that multinationals account for about 60% of global trade in goods and services, and so potentially represent a significant risk to countries' tax bases - especially those like Australia with relatively 'open' economies. As a result, multinationals are intensively scrutinised on an ongoing basis.

The large business segment is a very significant contributor to revenue. It contributes approximately 17% of Commonwealth income tax, 55% of GST, 54% of fringe benefits tax, and 95% of excise revenue. They are major employers, consequently contributing around 35% of Pay as you Go Withholding tax on behalf of employees.

There has been a growth of company income tax collections from some $20 billion in 1998/99 to $32 billion in 2002/03. Large businesses represent over 60% of income tax collections from companies. Over recent years, the trend has been for the growth in company tax collections to outstrip growth in GDP.

In a general sense the tax risks we see in the large business market are around complex planning arrangements that exploit grey areas of the tax law. It is an area of great interest to the community, and to media commentators.

We have a strong and successful active compliance program that assesses risk in this market through the use of sophisticated economic modelling tools and through the profiling of businesses by comparing them to market norms. Based on this risk assessment we utilise a combination of broad-based audits (particularly with the largest corporates) and industry and other specific-issue audits.

In recent times, we are seeing a change in the attitude of senior management of many large companies. They are seeking a more cooperative relationship with us as their awareness of tax as a corporate governance issue for large businesses increases. We are enthusiastic about utilising this opportunity to increase awareness of tax issues but also to see if we can develop more co-operative approaches to ensuring future compliance. The development of Advance Pricing Agreements to address transfer pricing issues is an early example.

Recently the Commissioner wrote to the chairmen of listed companies in Australia with his views on the role they could play in a governance sense when decisions are made on tax issues. He enclosed our Large business and tax compliance booklet, published last June. His letter includes ten suggested questions boards could ask to help them with governance. Both the booklet and this initiative have been generally well received.

Small-medium enterprise segment

The SME segment is a key focus for the up-coming 2004/05 compliance program, as is the micro business segment. We are reshaping and upgrading our approaches because of the nature of the risks we are seeing in these markets. I’ll give some more detail on our up-coming compliance program for both SMEs and micro businesses in a minute, but first, some detail on our current compliance approach.

Businesses in the SME segment display different characteristics depending on their size and complexity. Typically, businesses with a turnover of less than $10 million use simple business structures, with 65% being single entity companies. Businesses with a turnover of more than $10 million are using structures similar to those used by large corporations and we are seeing similar tax planning issues emerging.

SMEs account for around $32 billion, or 20% of Tax Office revenue. Around 1.8 million Australians are employed by SMEs, so Pay As You Go Withholding plays a big role, contributing 21% of total Pay As You Go Withholding revenue. GST contributes 26%, income tax 20%; Fringe Benefits tax 1.7%, Excise 1.3% and Superannuation 0.4%.

98% of SMEs use a tax agent to lodge their income tax return, however 75% receive their activity statements directly. Tax agents continue to be relied upon for advice on more complex issues.

In the SME market the current year’s (2003/04) compliance approach has two key elements:

an ongoing program of activities to make sure that small to medium enterprises meet their basic tax obligations around registration, lodgement, payment and the claiming of refunds; and
analysis and follow-up of information from activity statements, tax returns and other internal and external sources that identifies other compliance risks, particularly focused on ensuring the correct tax liability has been calculated.

After undertaking extensive data matching and GST walk-in audits, we’re finding fewer SMEs operating outside the system. We believe the market understands and routinely complies with basic GST obligations – 97% of SMEs lodge their BAS on a regular basis.

We are beginning to ramp up our profiling of businesses by comparing them to industry norms. As I mentioned earlier, particularly at the top end of SME, we are beginning to see many of the tax planning features characteristic of the large business market so we are starting to use economic modelling tools and other techniques currently used within the large business market. Key focus areas include income returned and deductibility of expenses claimed, financing arrangements, international dealings (especially with related parties), classification of supplies for GST, capital gains tax, losses, research and development claims, shareholder loans and capital allowances. We are also focusing on international tax issues such as transfer pricing and flows of funds to and from tax havens.

Micro business segment

The micro business segment comprises 2.5 million clients, that’s about 96% of all active registered businesses. However, while the segment is our biggest business segment, not surprisingly it is our smallest in terms of revenue contribution. The segment accounts for about 10% of the Commonwealth revenue.

The segment is characterised by its diversity, although over 60% is involved in:

Finance;
Property and business services;
Construction services; and
Primary production.

Around 80% of micro businesses have an annual turnover of less than $200,000. Most micro businesses are family businesses with few or no employees, and two-thirds operate from home. Many are sole traders or family partnerships.

About 95% of the micro business segment relies on tax agents to prepare their income tax returns but only 55% use a tax agent to prepare their activity statements, and this percentage is declining.

Our compliance focus this year is looking at ensuring businesses are aware of and meet their basic tax obligations, to see that they are correctly registered in our systems, to provide information about record keeping requirements and debt and lodgement issues. Around 60% of the Tax Office’s debt holdings are in the micro sector (this doesn’t mean 60% of micros are in debt!)

We’re looking closely at specific industries operating in the cash economy, such as restaurants, taxis and barter. And, following the third Cash Economy Task Force Report, we’re developing strategies to focus on business-to-consumer transactions in the cash economy.

We are also concerned about the use of tax havens for business and investment purposes, fuel grant schemes, self-managed super funds and excise fraud and evasion.

Individuals segment

The individuals market is our biggest segment, with 10 million taxpayers. Most are salary and wage earners. They contribute around 40% of Commonwealth revenue.

Around 75% of individuals use tax agents to prepare their tax returns. The tax affairs of individuals have increased in complexity as more individuals are earning income from investments in property and shares, and have to deal with the income and deduction rules applying to these more sophisticated investments.

We take a leveraged approach, which includes a reliance on tax agents and the use of direct mailouts to taxpayers, backed up with specific issue audits where necessary, for example, in cases involving rental income expenses. We conduct threshold system checks and match data with banks and other organisations, such as Centrelink. Datamatching with Centrelink is also a major contributor to their audit program.

On the other hand we are also making a conscious effort to inform individual taxpayers of their entitlements to credits and offsets such as the baby bonus and family tax benefit. Tax agents have told us, via surveys, our services to this market are good.

Work-related expenses remain an area of focus for compliance activities. These expenses account for around 60% of personal deductions for individuals. Trends in claims for work-related expenses have fluctuated over the past few years due in part to workforce patterns and economic trends. However, we remain concerned about the increase in the average amount of deductions claimed which is suggestive of some intentional over-claiming. We will continue to focus on work-related expenses next financial year, but more on that later.

We’re also concerned about rental expenses. The number of individual rental investors providing rental schedules to the Tax Office has increased from approximately 49,000 in 1998-99 to 1.4 million in 2002-03, an enormous growth. By 30 June 2004, we will have contacted around 23,000 individual rental investors – with around 3,000 audit contacts and 20,000 letters.

A related area of concern is capital gains on the sale of shares and property. Again, more on what we’re doing next financial year later.

Not for profit and government segment

There are 700 000 non-profit organisations, but only 170 000 of them are in the tax system – 94% of these are companies, and the remainder trusts. The combined annual turnover of non-profit organisations in Australia exceeds $27 billion.

The 30 000 largest non-profit organisations employ 8% of Australia’s workforce. So, while these organisations pay less than $1 billion in tax, their role is significant because they collect around $5 billion of tax paid by their employees, representing around 5% of total PAYG withholding.

Government organisations include federal, state, territory and local government bodies.

The not for profit and government market segment is generally highly compliant and most of our efforts are in help and education, although we do follow up on occasional non-compliant behaviour.

Specific focus areas – evasion and fraud

In addition to our market segment-based strategies, we have a number of specialised areas of focus that cut across all markets. To address these we establish a task-force or, where necessary, form a new division to bring a strong corporate focus to the particular area. Aggressive tax planning is one such area that has been well publicised. Today I’d like to briefly mention another specific focus area: evasion and fraud.

We believe the vast majority of taxpayers try to do the right thing, but a small minority are determined not to comply and, in some cases, directly undermine the tax system.

About a year ago (July 2003) we brought our fraud and evasion investigation activities together into one division named Serious Non-Compliance. We have nearly 500 people working in this area and they investigate a whole range of suspect activity, including GST refund fraud, complex income tax fraud and excise fraud - such as trading illegal tobacco and fuel substitution. An emerging area of concern is identity crime as a vehicle to conduct tax fraud. This is a society-wide risk, and we are working with many other government and law-enforcement agencies on a systematic approach.

A high priority project we have underway is detecting otherwise legitimate professionals operating outside the tax system. The impetus for setting up this focus came from a project that investigated New South Wales barristers and solicitors working outside the tax system. You’ll recall this project generated a lot of media coverage, mainly around poor payment behaviour detected, particularly the use of bankruptcy provisions to avoid payment of debts. We have now expanded our focus to risk assess barristers and solicitors nationally as well as, architects, medical practitioners and accountants.

We have identified only a very small number of architects, barristers and solicitors working outside the system and we’ve helped some others bring their affairs up to date. We’re pleased that these numbers are low. We are continuing to profile accountants and medical practitioners.

I’m sure you will be particularly interested in the results of our risk assessment activities to detect accountants, including tax agents, operating outside the system. The first step has been to match professional association membership records against our records.

You’ll be pleased to hear that, from our initial results, there does not seem to be a problem with tax agents working outside the system. Of over 143 000 records received from accounting professional associations 1149 are being reviewed because they don’t match with our records. However, early indications show the reason for no match is mainly due to a change of name.

Compliance focus in 2004/05

Our compliance program is designed to roll forward, keeping a balanced approach across the community while adapting our strategies to treat new risks as they emerge. We have just completed the risk assessment part of our planning cycle concluding that, for most areas, we will be continuing the same focus in the coming year, with some finetuning.

However in two markets and two revenue products we believe we need to significantly reshape our approach. These are the SME and micro business markets and Capital Gains Tax and Superannuation products.

You will have heard in Tuesday’s Federal Budget, the Government will provide an additional $216.4 million over four years to the Tax Office that will address a number of these risks in the SME market; and capital gains tax and superannuation products.

As the Treasurer also said on Tuesday, there are a significant number of individual taxpayers claiming high levels of work-related expenses last year, with the majority of these claims coming from tax agents. We will continue our existing work-related expenses compliance activities, while increasing our focus on the small, but significant, percentage of agents where there is a high risk of over claiming by their clients and poor return preparation quality controls. More on tax agents later.

SME market

First, let’s look at our up-coming compliance approach in the SME market.

In 2004/05 we will undertake a greater number of audits and reviews with an increased focus on larger businesses.

As I mentioned earlier we are seeing SMEs starting to mirror many of the tax planning features characteristic of large businesses. So the Tax Office will adapt the client risk profiling and treatment capability developed for the large business market, and develop leveraged approaches on these more complex issues, to improve effective coverage across this market.

We will increase our risk-profiling activity in the SME market, measuring tax performance against economic performance. We may risk-profile at whole-of-market level, or by industry, issue, revenue product, entity or whole-of-enterprise. Our focus on GST and income tax will continue and we will increase our scrutiny around employer obligations including PAYG(W), fringe benefits tax and superannuation guarantee.

To undertake this risk profiling and analysis we will continue to use sophisticated computer modelling, and source data from publicly available information, income tax returns and activity statements.

Particular focus areas will be: Claims for accelerated deductions for expenditure incurred on research and development activities; income tax treatment by complying super funds on income distributed by trusts; treatment of losses; treatment of capital gains and the application of the small business concessions; the use of service trusts by professional businesses; and the GST treatment of significant transactions such as the sale of high value assets and share floats.

We have also issued and will be following up a number of taxpayer alerts, expressing our concern regarding advisers promoting property development arrangements that seek to avoid the application of GST to sales of new residential property.

We may contact the SME to better understand the business and its operating environment. We will endeavour to resolve issues during the reviews by inviting clients to voluntarily correct their tax liability. Where material issues remain unresolved we will escalate the case to an audit or other compliance response, depending on the individual circumstances of each case.

We will continue to focus on ensuring businesses meet their basic tax obligations around registration, lodgement, payment and claiming of refunds. We will monitor taxpayer behaviour and take early action – such as calling, writing or visiting the client. For example, unusual patterns of payments identified through the tax collection system will be followed up to determine the reason for any significant variations.

We recognise employer obligations such as withholding tax from employees and other workers; fringe benefits tax and superannuation guarantee are inextricably linked so we are developing an integrated approach to assuring employer obligations are met. Data matching, reviews, audits and field verification activities will increase which, combined with additional risk analysis and intelligence gathering, will enable better understanding of compliance issues in these areas. Such activities assist in ensuring obligations on behalf of employees are met, increasing entitlement security as well as the integrity of large tax bases like PAYG(withholding).

We will phone employers when we detect discrepancies; all of our risk reviews and audits will incorporate some basic employer obligations compliance checks and we will undertake some specific employer obligation reviews.

Micro market

The micro business market is another area of our program where we think we need to reshape our strategies. We do not think this warrants a resource shift but we believe that with improved profiling of this segment we can better tailor our approaches.

We will continue our emphasis on helping and educating businesses to make sure they are aware of their tax, excise and superannuation obligations, particularly their record-keeping obligations.

Our biggest challenge in this segment is how to tailor our approaches given the numbers involved and the diversity of businesses. We are starting to develop more leveraged approaches to the vast majority of taxpayers (similar to our approach in the individuals market) including more extensive use of data matching but will also continue a more intensive focus on areas of key risk such as the cash economy. And we will be increasing our coverage at the top end of this market.

Superannuation

Superannuation is becoming an increasingly important public issue. We are experiencing increasing demand for help and support from the community and are detecting some key compliance risks. We have detected a significant risk of non-compliance in self-managed super funds. We also have concerns about the level of compliance with the superannuation guarantee and the superannuation surcharge. We will also be increasing our focus on reuniting people with their “lost” superannuation entitlements – there is around $7.3 billion in superannuation contributions where funds have lost contact with their members.

One area I’d particularly like to highlight is Self managed super funds. They account for more than 21% of the $560 billion invested in superannuation and their numbers are growing dramatically.

Since the Tax Office took responsibility for these funds from APRA in 1999, their numbers have grown dramatically. There are now around 300 000 self managed super funds, up from 178 000 four years ago and more than 2 000 per month are being established.

Our early approach was largely about providing help and assistance. While we will continue to assist those managing self managed super funds, we are now rebalancing this approach, by applying a firmer hand where we believe those with the relevant responsibilities have not acted appropriately and should know better. As part of this approach, we will have a greater auditing presence, reviewing the operation of significantly more funds.

We will also follow up new fund registrations to ensure trustees are aware of their responsibilities. One of these is that they are “fit and proper persons”. We will also check that their fund has been established for the sole purpose of providing retirement benefits.

Recent legislative changes now mean that self managed, fund approved auditors must advise the Tax Office if they become aware that trustees have not met their obligations. We will investigate these auditor notifications as part of our ongoing compliance activities.

We will be releasing a booklet focussing on compliance issues for self managed super funds. The working title for the publication is "It's your money ... but not yet!" This emphasises the core objective of our regulatory role which is to ensure the funds operate to achieve the policy objective of providing retirement income for members.

Capital gains tax

Capital gains tax is emerging as an area of high risk across all markets. We are getting feedback from both taxpayers and their agents about the complexities of the capital gains tax system and are working with these groups to make it easier to comply. On the other hand, we are seeing some large capital gains made on property simply not being included in returns. As a result, we will be increasing our focus on capital gains tax with the introduction of an ATO wide compliance strategy reaching across all of the markets. A particular focus will be in the individuals market. The ATO received additional funding in the budget and will review our education products and increase our capital gains tax and rental investment audits.

We will also increase our capability to identify capital gains risks. For example, we will make greater use of our data matching capability in areas such as property and share disposals. This includes matching State revenue office sales information against net capital gains.

Our current focus is heavily on real property, reflecting the gains made in residential property over the past five years. As part of our broad data-matching initiative, we have been able to identify trends and likely areas of risk of under disclosure, where verification work has been carried out. For example, we are examining sales of high value/high growth Gold Coast properties. The project involves 114 audit cases plus an additional 112 pre-lodgement awareness notices. So far we have seen approximately $2m of tax raised from this project, with another $3m tax expected from selected but unfinalised cases.

Our active compliance focus will move onto the sharemarket in early 2005, reflecting the gains now being evidenced in shares, around 15% over the past year. We plan a pilot that will match data from share registries against net capital gains in return forms and CGT schedules.

Another area of priority is to increase our effort on education in the individuals and micro markets. Agents are telling us that they see many individuals with capital gains tax difficulties caused by their poor record keeping or lack of knowledge of the capital gains tax implications of the transaction. We recognise that it is too late to deal with these issues at tax time and after the transaction has been completed. We will be working with intermediaries involved in these types of transactions - for example stock brokers, financiers and conveyancing lawyers - to get capital gains tax information to taxpayers when they acquire assets that may give rise to future capital gains tax liabilities. We are also developing a record keeping tool to assist taxpayers in meeting their capital gains tax obligations.

Tax agents and the role of intermediaries

As tax agents, you play a pivotal role in all our markets. This is why we believe it is important that we publish our compliance approaches so that you are well informed and can assist your clients appropriately.

It’s also important that the integrity of the tax agents is maintained, hence the outside the system project targeting accountants that I mentioned earlier, and the latest budget announcement that we will be leveraging compliance in the work-related expenses area through tax agents, also mentioned earlier.

We are also continuing to co-design our services with you, to streamline your interactions with us.

An example you’ve all heard about is the tax agent’s portal – it’s a best-seller! Introduced in October 2002, the portal is now used by about 86% of active agents. It’s received over three million hits this year and, in April, there has been an average of 151 new agents accessing the portal per week. Our latest agent survey shows that for the first time it is the preferred method of interacting with us (44%) with telephones shifting to second preference (40%).

The tax agents’ portal heralds a whole new generation of service possibilities to increase the range of support services we provide to all agents. This currently includes direct access to client account information. Agents can, in real time, update client registration details regarding postal and business addresses and contact details. They can also send messages to the Tax Office via secure messaging. In the future, more real time facilities will be available such as activity statement lodgement and additional client detail updates. Future services may also include access to risk analysis tools and details about our compliance program approaches.

Another new tool is the Compliance Toolkit, now available on ato.gov.au under quick links on the Tax Professionals home page. It’s already proving to be a hit – in April it received over 7000 hits.

The toolkit consolidates compliance activities into an easy electronic reference guide with activities listed alphabetically ranging from the accounting profession to the motor vehicle industry to working holiday makers.

The toolkit provides a snapshot of more than 60 activities outlining the approach we take and creating an awareness of what attracts our attention.

By being open about our compliance activities we hope to make it easier for tax agents, and the community, to comply. Tax agents, who were involved in the co-design process, have already told us that they will be able to use the toolkit to educate clients about meeting their taxation obligations.

The toolkit provides links to fact sheets, media releases, schedules, calculators, industry information and frequently asked questions. There is also information about what to expect if a client is selected for a field activity, as well as explanations of BAS reviews, walk-in registration and lodgement checks, and other compliance products.

The toolkit complements and cross references to information included in the Compliance Program and it provides easy access to industry benchmarking information.

Very soon we will be using the Compliance Toolkit to update you regularly on the results of our activities.

Conclusion

In conclusion, in the past twenty months we have experienced significant change, we are preparing for publication of our third compliance program including the results of the second. We are about to publish the third in the series of special focus booklets, this one on self managed super funds. We are refining our risk assessment approaches for each market and adapting our compliance strategies to address them. And we have put in place a compliance toolkit that allows you to drill down to more detail so you can assist your clients. Soon it will include results of our approaches.

As you can see, we’re in this together. You are our link to many of our clients - our taxpayers. Our sincere hope in providing these products to you and the community is if we provide you with the best possible information we can on our compliance activities it will help you support your clients manage their tax compliance.

I hope today’s summary of the compliance journey so far has been informative. I also hope it explains our compliance program in an open and transparent way.

As you can see, we don’t suffer from a lack of challenges, but we deal with them in the knowledge that we must maintain the integrity of the tax system we all support.

Last Modified: Friday, 14 May 2004

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