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  • Action Differentiation Framework

    The Action Differentiation Framework (ADF) is our strategic approach to engaging with public and multinational businesses.

    The way we engage with you is tailored or differentiated based on our understanding of the complexity of your affairs, informed by:

    • size
    • transparency of your engagement with us
    • choices and behaviours evidenced in your tax affairs
    • the level of risk you exhibit.

    The ADF expands upon the Top 100 risk categorisation approach and allows us to:

    • use resources efficiently, allocating them to priority focus areas and where specific attention is required
    • focus on the principles of obtaining justified trust.

    Engagement frequency

    Under the ADF, you are grouped into populations based on your total business income.

    Population, total business income and our level of engagement

    Population

    Total business income

    Our level of engagement

    Top 100

    >$5b or Market leader

    Ongoing via Key taxpayer engagement approach

    Top 1000

    >$250m

    Periodic via Top 1000 Tax Performance Program

    Medium

    $10m – $250m

    Periodic

    Emerging

    <$10m

    Periodic

    If you fall into the top 100, you will receive ongoing one-to-one tailored engagement from us.

    If you fall into the top 1000, you will receive periodic one-to-one tailored engagement from us.

    If you fall into the medium or emerging population, you may receive broader engagement, like campaign and nudge communications.

    Engagement experience

    The ADF guides how we tailor our engagement with you across a range of services and approaches based on the following:

    • Partnering – we partner with you to maintain good compliance.
      • If you are willing to engage and are transparent in maintaining compliance, we will partner with you to deliver services in a timely and efficient manner to help you meet your tax obligations. We will adopt a lighter touch approach to our compliance interactions with you, reducing your compliance costs.
       
    • Encouraging – we encourage you to address our concerns.
      • If you take positions relating to complex arrangements giving rise to significant tax risks, you will be urged to address our concerns. We will encourage you to improve our level of assurance over your affairs through the use of tailored services and approaches, according to your particular circumstances. We'll also work with you to improve your future transparency and compliance.
       
    • Influencing – we take firm action to influence you to improve your compliance.
      • If you are generally not transparent and consistently take high risk positions, we'll adopt a high-touch, intensive, approach to ensure risks are addressed quickly. The services and approaches we take will be tailored to your particular characteristics and behaviours and we'll adopt firm approaches, like formal powers for information gathering, until you improve your transparency and compliance.
       

    See also:

    • For further information on the ADF, email ADF@ato.gov.au
    Last modified: 08 Jul 2019QC 57568