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  • GST streamlined assurance review – what we need from you

    We're committed to making sure large multinational and public companies pay the right amount of goods and services tax (GST).

    GST streamlined assurance reviews will give greater certainty about meeting your tax obligations.

    What we need from you

    If your business is under review, we've sent you a letter outlining the details of our meeting. We'll tailor the review to your unique business profile, and work with you to get the evidence to assess whether you're meeting your GST obligations.

    The letter we sent requested that you send information to help with our review. Our focus, at this early stage, is on information and documents that should be readily available. The information we need you to provide is listed below.

    We will write to you when we have finished our review to explain the outcome.

    Structure and business activities

    1. Organisational structure

    Provide the latest detailed organisational structure for the Australian business representing the economic group.

    2. GST group

    • Provide the latest GST reporting structure including GST groups and other GST reporters. If applicable, include any trusts.
    • Provide a reconciliation of your consolidated accounting group structure (for financial reporting purposes) to your GST reporting structure.
    • Provide the ABN of each entity.

    3. Business activities

    Provide a brief description of the activities carried out by each of the entities of the GST group, and consolidated accounting group, in the organisational structure.

    4. Acquisitions, mergers and disposal of entities

    • Provide details of acquisitions, mergers and disposals of any business entities within the indirect tax zone in the review period, including:  
      • a brief description of the entities acquired, merged or disposed
      • the gross value of the transactions and the respective GST treatments.
    • Provide details of any anticipated or planned restructures of the GST group.

    Tax governance and risk management

    5. Consideration of our Tax risk management and governance review guide

    The Tax risk management and governance review guide sets out principles for board and managerial level controls relating to income tax, excise and indirect taxes, and what we consider best practice for large public groups and multinationals.

    • Describe your approach to the guide, including whether you have  
      • conducted a gap analysis of current policies and procedures against our guide and identified compensating controls where applicable
      • applied the self-assessment procedures to test and obtain evidence of the controls operating effectively.
    • If the self-assessment procedures have been applied, provide the self-assessment report including all the supporting documentation.
    • Provide details of any control deficiencies and identified impact on business activity statements, including actions taken to remediate the identified deficiencies.

    6. Corporate governance

    Provide a copy of your corporate governance framework, identifying the practices driving and supporting good governance.

    If you have recently undertaken a self-assessment/gap analysis there is no requirement to provide this information.

    7. Tax governance and controls framework

    Provide the most recent documentation outlining your tax governance and risk management, including:

    • tax governance manuals, guidelines or policy available to staff
    • key personnel and decision makers in the tax/finance team including their areas of responsibility/specialisation
    • evidence of staff training on tax governance
    • tax compliance outsourcing arrangements and third party preparers
    • how tax compliance is incorporated into the governance structure
    • an overview of how the use of external advisors is incorporated in the tax governance framework and the circumstances when external advice on a GST issue is sought
    • how frequently this documentation is reviewed
    • copy of any communications (within the last 12 months) to the board and senior management in relation to escalation of GST issues, including, but not limited to, minutes, agenda items and emails
    • Confirm whether you have a periodic program to test the operating effectiveness of your control framework by way of internal or external reviews. If yes
      • provide a copy of the program and details of the scope and outcome of the most recent review.
      • was the program and review reports tabled to the board? If yes
        • provide supporting documentation, including but not limited to agenda items, minutes, emails and remedial plans proposed by the board for any tax control failures identified.

    If you have recently undertaken a self-assessment/gap analysis there is no requirement to answer this question.

    8. Overview of information technology systems

    • Provide a business systems architecture diagram outlining how sales and acquisitions flow through the systems.
    • Provide flow charts or describe the end-to-end ‘order to cash’ and ‘procure to pay’ process with reference to how financial information is captured and stored to account for transactions.
    • Provide an overview of the accounting system (or systems) you use to capture transactional data.
    • Provide a list of tax codes and respective rates.
    • What are the procedures for changing/updating the classifications of supplies/acquisitions and related master files and tax codes?
    • Provide a summary of controls in place to ensure the accuracy and integrity of data input and processing.

    9. Business Activity Statement (BAS) preparation process

    Provide:

    • an overview of the BAS preparation process including flowcharts if available
    • a copy of the BAS preparation manual or written procedures including who prepares and reviews the BAS prior to lodgment
    • details of staff training provided in relation to the BAS preparation and GST technical matters, data input and processing
    • review and authorisation process
    • skill and qualification of staff preparing and reviewing the BAS
    • overview of the accounts payable and accounts receivable process
    • an overview of reconciliations of reported GST figures to relevant general ledger accounts and financial statements.

    10. Information technology (IT) systems governance

    • Provide a copy of the long term and short term IT strategic policy outlining  
      • communication process with the board
      • alignment between business and IT strategy
      • staff roles and responsibilities
      • access controls to logical and physical assets
      • business continuity plan
      • disaster recovery plan
      • outsourcing practices or guidelines.
    • Provide the information systems architecture diagram used in accounts receivable (AR), accounts payable (AP), BAS preparation and delivery processes outlining  
      • flow of transactional data (both supplies and acquisitions)
      • a brief functional description of each system.
    • What IT control framework do you have in place to support  
      • your business objectives
      • monitor and evaluate IT performance
      • monitor and evaluate internal controls
      • ensure compliance with external requirements.
    • Provide details of any IT project you have implemented affecting AR, AP, BAS preparation and delivery processes or plan to implement in the next 12 months, including  
      • business process changes
      • project management methodology
      • make-up of the project team
      • post-implementation review results.

    11. Tax risks flagged to the market

    • Describe your processes to identify tax risks flagged by us (or other bodies) to the market.
    • Confirm whether you have entered into arrangements the same or similar to that described in any Taxpayer Alerts, Public Rulings and Practical Compliance Guidelines. If yes
      • identify the relevant Taxpayer Alert, Public Rulings and Practical Compliance Guidelines
      • provide a brief description of the arrangement and the GST position taken
      • provide documentation, including but not limited to risk register, relevant minutes and emails of board’s endorsement for GST positions adopted by management.

    12. Significant and new business transactions

    • Describe your criteria for classifying a transaction as significant
    • Detail assurance processes or controls currently in place to identify, process and review significant and new transactions to ensure the correct GST classification is applied
    • Provide details of any significant and /or new transactions for the review period, such as  
      • significant capital acquisitions
      • restructures
      • new products, services, business lines and divisions
      • international dealings
      • financial supplies including capital structures and financing.

    13. Alignment between accounting and tax results

    • Provide a copy of your most recent externally audited financial statements.
    • Detail processes in place to reconcile GST figures reported on your BAS to accounting figures reported on financial statements. If conducted, provide the reconciliation for the most recent accounting year.
    • Identify how you monitor BAS reporting trends, including changes in the mix of supply classification and reconciliation of unexpected variances.
    • Describe the process to escalate any significant deviations/trends or unexpected variances to senior management.

    Other questions

    We might ask additional questions about known industry risks or significant issues which may only be relevant to your business (for example financial supplies, GST on low value imported goods, digital supplies).

      Last modified: 05 Dec 2018QC 56546