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  • Key taxpayer engagement

    Key taxpayer engagement (KTE) is the name of an overarching whole-of-tax approach used to engage the largest public and multinational businesses. The KTE incorporates a multi-tax or whole-of-tax approach wherever practical and desirable.

    Under the KTE approach we aim to work with key taxpayers in real-time on significant transactions to ensure they obtain tax outcomes consistent with the law and with our advice and guidance to market.

    KTE is directed at clients with the largest impact on the tax system. These clients are described as the 'Top 100' (formerly known as ‘higher consequence taxpayers’ under the risk differentiation framework).

    How the KTE works

    The Action Differentiation Framework (ADF) and other knowledge we have about the client is applied to determine the appropriate whole-of-tax approach to engage with the taxpayer, based upon our understanding of their:

    • risk position
    • circumstances
    • choices
    • behaviours.

    This whole-of-tax approach requires our staff to work as a virtual team to integrate and coordinate activities and approaches in engaging with the client. Where practical the team will coordinate activities to identify and resolve risks, across different taxes.

    This team will tailor the services provided to the client and determine the intensity of engagement based on the above criteria.

    Positive and sustained compliance behaviour and co-operation will result in enhanced services and a streamlined approach to assurance.

    Less compliant behaviour and less cooperation will result in standard services and greater intensity in assurance activities.

    How the KTE approach is different

    Staff from different tax areas will work together to ensure:

    • information obtained from the client by one area is shared and aggregated to give all staff a more complete picture of the business
    • engagements for each tax are coordinated to minimise the impact on the client and may be conducted jointly where it is practicable or necessary.

    Engagement will be ongoing with a client centric focus. Our aim is to work purposefully and cooperatively with Top 100 clients.

    Our approach will:

    • balance the services you receive and the assurance requirements you have to satisfy according to your risk profile
    • take a more whole-of-tax approach, combining engagement on
      • income tax
      • indirect taxes
      • petroleum resource rent tax
    • provide you with a tailored approach to your dealings with us, taking into account the complexities of your business and industry.

    Annual compliance arrangements

    As part of the key taxpayer overarching engagement model, annual compliance arrangements (ACAs) will continue to be offered to taxpayers who demonstrate the appropriate characteristics.

    See also:

    Justified trust and key taxpayer engagement workshop outcomes

    In partnership with the Corporate Tax Association (CTA) we co-hosted a series of workshops in October and November 2017, focussing on justified trust and key taxpayer engagement.

    Together we hosted seven workshops, with over 172 CTA members representing more than 100 corporates and about 300 ATO staff in attendance. We also met with key advisors in early 2018 to discuss the impacts of justified trust and key taxpayer engagement in the context of the workshop material.

    The final outcomes from the workshops have been captured in a shared ATO and CTA outcomes document:

    Last modified: 23 Sep 2020QC 50429