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  • Top 1,000 combined assurance program

    The Top 1,000 combined (income tax and goods and services tax) assurance program is part of the Tax avoidance taskforce. It has been established to replace the Top 1,000 tax performance program that is ending in December 2020.

    Specialist tax performance teams will engage with each taxpayer using tailored assurance approaches. We seek to increase our assurance that large public and multinational groups are reporting the right amount of income tax and goods and services tax (GST) or identify areas of tax risk for further action.

    The new program provides large businesses with an opportunity to gain greater certainty about their tax outcomes and the effectiveness of their tax governance frameworks. It also provides an objective mechanism for large businesses to understand how their tax profile compares to others in the market and their peers.

    The program builds on previous assurance engagements. This enables us to 'top up' our understanding. We will not seek the same level of information as that required in your previous assurance review unless there are significant changes in your business.

    The reviews provide an opportunity to improve assurance ratings obtained under previous reviews as we review improvements and steps taken to address our concerns.

    By following our guidance and recommendations and providing information requested in a timely manner, taxpayers are less likely to experience protracted reviews or follow on compliance activity.

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    Who the program covers

    The Top 1,000 combined assurance program covers large public and multinational companies, with income tax and GST turnover above $250 million. This includes taxpayers we've engaged with through income tax and GST assurance reviews.

    This program doesn't include taxpayers in the Top 100 Program.

    Our combined assurance review

    We apply our justified trust methodology in our combined assurance reviews. Each review has an income tax and a GST component. Where we have already engaged through an income tax or GST assurance review, we will tailor the review based on the outcomes of those previous engagements.

    Income tax component

    The income tax component of the review seeks to increase our level of assurance that you're reporting the right amount of income tax and identify areas of income tax risk for further action.

    If we have engaged with you through an earlier income tax assurance review, we seek to ‘top up’ our income tax assurance and focus on what has changed since that review. We also check you've addressed any recommendations from your previous review. You will be able to improve your assurance ratings by following these recommendations. We are publishing more guidance to help you improve your assurance ratings for common areas where we do not obtain assurance.

    If we haven't engaged with you through an income tax assurance review, the income tax component of the review will be like a Top1,000 streamlined assurance review and cover a four-year period.

    GST component

    The GST component of the review seeks to increase our understanding of your GST governance frameworks and identify areas of GST risk for further action. We focus on the latest income year for GST.

    Where we identify material GST risks you may be referred for a Top 1,000 GST assurance review.

    If we have engaged with you through an earlier GST assurance review, we leverage our understanding of your business and seek to ‘top up’ our understanding of your GST governance frameworks and your GST risk profile. We also check that you addressed any recommendations from your previous review.

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    Assurance approaches guidance

    We have published guidance about our assurance approaches to help you prepare for your review and obtain higher assurance outcomes. The findings from the Top 1,000 tax performance program is also available to help you understand the key areas that attract our attention where we are unable to obtain assurance. You can use this guidance to help you prepare and understand how to improve your ratings.

    We continue to update our guidance to help you obtain better outcomes from the review.

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    Early notification of your review

    We will notify you before we start a combined assurance review and provide you with our request for information giving you time to complete responses.

    You will have a short period of time to consider whether to make a voluntary disclosure in respect of any errors or omissions.

    Our request for information is a list of questions that asks you to provide some of the information in a standard template format. On receipt of the information, we may follow up with additional questions where required.

    We recognise that many large businesses and their employees are currently being affected by COVID-19. We understand that circumstances and needs may vary between large businesses. While we have clear commitments, we continue to be empathetic to your needs, understanding the continuing adverse effects of COVID-19 on your business operations.

    We will work with you to adapt the timing of the review to your circumstances.

    How we tailor your review

    We expect you to take steps to ensure you understand our assurance approaches to prepare for your review. We tailor the combined assurance review to your circumstances having regard to:

    • your assurance outcomes from any previous income tax or GST assurance engagement
    • the steps you have taken to address recommendations in previous income tax or GST assurance engagement
    • how you have applied our published guidance – we will ask whether you have considered and applied our public guidance relevant to your circumstances including, reviewing your tax governance using our Tax risk management and governance review guide and GST Governance, Data Testing and Transaction Testing Guide
    • how you respond to our request for information for your combined assurance review – you should provide us with timely, accurate and complete responses to our questions.

    Importance of timely and complete responses

    We consider the provision of timely and complete responses to our request for information may indicate the presence of stronger tax governance frameworks and a willingness to engage with us to obtain better review outcomes. Where this occurs, we will seek to tailor your engagement with us through:

    • shorter reviews
    • shorter combined tax assurance reports
    • ‘lighter touch’ engagements.

    If your responses don't meet our expectations, it is likely that you will be asked detailed questions and experience a longer more intense review process.

    What to expect following a review

    Following a combined assurance review we will share our findings with you, including:

    • discussing the areas where we have assurance you reported the right amount of income tax
    • any identified income tax risks
    • our assessment of your GST risk
    • whether we are referring you for a Top 1,000 GST assurance review.

    We will provide separate ratings for income tax and GST. For income tax we may recommend specific actions to obtain greater assurance or address identified tax risks and may follow up on these recommendations. We may also refer you for further compliance activity.

    For GST, we may recommend specific actions to address identified GST risks and follow up on these recommendations. Where we identify GST concerns, we may refer you for a Top 1000 GST assurance review.

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    Last modified: 10 Sep 2020QC 63637