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  • Findings Report Top 1,000 Tax Performance Program (income tax)

    The ATO Findings Report summarises the key findings for the Top 1,000 Tax Performance Program as at March 2019. Our findings were sourced from over 280 streamlined assurance reviews.

    These findings will help you to understand how we apply the justified trust methodology to obtain greater assurance that large public and multinational taxpayers are paying the right amount of tax or identify areas of tax risk for further action.

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    Top 1,000 tax performance program

    The Top 1,000 tax performance program was established in July 2016 to obtain greater assurance that large public and multinational economic groups are reporting the right amount of income tax or identify areas of tax risk for further action.

    The program covers those large public and multinational economic groups with an annual turnover above $250 million. It does not cover taxpayers that continuously engage with us through our Top 100 program.

    The program also covers a diverse range of groups in terms of their ownership, business models, industries and size. Often these groups consist of one tax consolidated group. Where the group has more than one taxpayer we usually review those taxpayers with turnover above $250 million. In appropriate circumstances we may review smaller taxpayers within the group.

    Our approach

    The program applies a consistent, structured approach in our reviews. A dedicated program team supports the consistent application of this approach by our specialist assurance teams that are located across Australia.

    Our teams engage with each taxpayer using streamlined assurance reviews (reviews). Typically a review will cover the last four income years.

    We apply the justified trust methodology and seek to obtain assurance of the following four focus areas:

    • that appropriate tax risk and governance frameworks exist and are applied in practice
    • that none of the specific tax risks we have flagged to the market are present
    • the tax outcomes of atypical, new or large transactions are appropriate
    • any misalignment between tax and accounting results is explainable and appropriate and the right amount of tax on profit from Australia-linked business is being recognised in Australia.

    This report outlines our findings as at end of March 2019, in respect of the four justified trust focus areas. It will be updated as our coverage of large public and multinational groups continues to expand.

    The program has expanded substantially since commencement and continues to evolve as we refine and improve our approach having regard to feedback from taxpayers and other key stakeholders.

    In response to taxpayer feedback, in late 2017 we published the ‘typical questions’ asked in a review on to assist taxpayers prepare the required information in advance of a review commencing. In June 2018 we started moving to ‘early notification’ where we contact taxpayers up to four months in advance of the commencement of the review.

      Last modified: 30 Jul 2019QC 59607