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  • Top 100 justified trust program

    Justified trust is a concept from the Organisation for Economic Cooperation and Development (OECD).

    We originally introduced the justified trust concept starting with the top 100 population in 2016.

    We complete justified trust reviews as part of the yearly pre-lodgment compliance review (PCR) and annual compliance arrangement (ACA) processes.

    In these reviews, we apply consistent rating categories to our overall level of assurance. We apply a high assurance rating where we have confidence that the taxpayer paid the right amount of tax for the period reviewed.

    Due to the size and complexity of taxpayers in the top 100 population, we expect that it may take some taxpayers a number of years to reach high assurance. We are working with each of the top 100 as part of the PCR and ACA processes to gain, and maintain a high level of assurance. We will tailor future engagements to focus on new, unassured areas and changes.

    See also:

    Top 100 Findings report

    Our Findings Report Top 100 Program (income tax) July 2020 covers our key findings from tax assurance reviews completed to 30 June 2020.

    These findings will help you to understand how we apply the justified trust methodology to obtain greater assurance that Top 100 taxpayers are paying the right amount of tax or identify areas of tax risk for further action.

    More information

    To learn more about the top 100 program, email us at

    Last modified: 25 Nov 2019QC 60472