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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 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
    • your risk appetite.

    The ADF expands upon the Top 100 risk categorisation approach and also allows us to focus on the principles of obtaining justified trust.

    Engagement frequency

    Under the ADF, you will fall into one of the following categories based on your total business income.

    Client category, total business income and our engagement

    Client category

    Total business income

    ATO 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 categories, you may receive broader engagement, like campaign and nudge communications to manage the greater number of clients.

    This approach allows us to use resources efficiently, allocating them to priority focus areas and where you require specific attention.

    Engagement experience

    The ADF considers your characteristics and behaviours and tailors our engagement with you across a range of services and approaches.

    You will be categorised into one of the following engagement experiences:

    • Partner – we partner with you to maintain good compliance
      • Those in the partner category 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 also adopt a lighter touch approach to our compliance interactions with you.
       
    • Encourage – we encourage you to address our concerns
      • Those in the encourage category will be urged to address our concerns with positions relating to complex arrangements giving rise to significant tax risks. The services we offer and approaches we take will be tailored to your particular characteristics and behaviours and we'll work with you to improve your future transparency and compliance.
       
    • Influence – we take firm action to influence you to improve your compliance
      • Those in the influence category are generally not transparent and consistently take high risk positions. We'll adopt a high-touch 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.
       

    More information

    For further information on the ADF, email ADF@ato.gov.au.

    Last modified: 25 Mar 2019QC 57568