Our public and private advice and guidance positively influences taxpayers to get their obligations right from the start, ensures a level playing field and addresses GST risks.
Advice and guidance
In 2024–25, we finalised 410 private ruling requests on GST issues, with 91% completed within 28 calendar days of receiving all the necessary information. This exceeded our service standard of 80%.
Table 6.1 shows a drop in our 2024–25 guidance request results to 84%, slightly below our service standard of 85%. We have provided training on our service commitments to staff to improve this result. We will continue to monitor and provide refresher training on a regular basis as part of our commitment to continuously improve.
Continuing the downward trend from previous years, finalised guidance requests decreased by over 300 this year to 1,501 requests.
This reduction can be attributed to our continued focus on providing modern, effective and timely public advice and guidance to support taxpayers at scale.
Since our mid-year report, we have published public advice and guidance explaining the Commissioner’s view on a range of GST topics including:
- how the GST law operates in relation to incorrectly charged GST
- supplies made to non-residents not in Australia
- supplies that are effectively used or enjoyed outside of Australia.
|
Request type |
2020–21 |
2021–22 |
2022–23 |
2023–24 |
2024–25 |
|---|---|---|---|---|---|
|
Guidance requests |
95 |
90 |
92 |
88 |
84 |
|
Private rulings |
99 |
96 |
92 |
85 |
91 |
Note: GST Performance Agreement Schedule A 9e. This is a service commitment. An 85% target applies for general taxpayer requests and an 80% target applies to private rulings.
|
Review rating |
2020–21 |
2021–22 |
2022–23 |
2023–24 |
2024–25 |
|---|---|---|---|---|---|
|
Rated as ‘achieved’ |
100.0 |
97.0 |
97.5 |
99.0 |
99.0 |
Note: GST Performance Agreement Schedule A 9f. Technical advice cases are assessed and rated for the accuracy of the technical decisions.
Dispute management
Objections
Addressing GST objections is essential to maintaining trust and confidence in the tax system.
Results for 2024–25 audit to objection transition rates as shown in Table 6.3 and created GST objection cases in Table 6.4 are similar to last year. Over 50% of objection cases arise from pre-issue GST compliance activities, in particular high-risk refunds.
Nearly 80% of all objections come from small businesses. Our GST compliance audit actions continue to account for approximately 90% of created GST objections. The majority are regarding:
- correct reporting risk, pre-issue and post-issue refund integrity cases
- GST property
- GST and ABN registrations and cancellations
- electronic sales suppression tools (ESSTs).
Resolved objections dropped (11.5%) this year as shown in Table 6.5. This aligns with a corresponding drop in allowed in full outcomes for streamlined investigations such as legitimate enterprise verifications for Operation Protego cases.
|
Activity |
2020–21 |
2021–22 |
2022–23 |
2023–24 |
2024–25 |
|---|---|---|---|---|---|
|
Audit to objection transition rate |
5.6 |
1.1 |
3.0 |
12.6 |
12.6 |
Note: GST Performance Agreement Schedule A 7c.
|
Activity |
2020–21 |
2021–22 |
2022–23 |
2023–24 |
2024–25 |
|---|---|---|---|---|---|
|
Audit-initiated |
267 |
528 |
1,519 |
1,748 |
1,760 |
|
Client-initiated |
138 |
137 |
201 |
204 |
213 |
|
Other |
2 |
0 |
1 |
0 |
0 |
|
Total cases created |
407 |
665 |
1,721 |
1,952 |
1,973 |
Note: GST Performance Agreement Schedule A 7a.
|
Activity |
2020–21 |
2021–22 |
2022–23 |
2023–24 |
2024–25 |
|---|---|---|---|---|---|
|
Audit-initiated |
426 |
413 |
1,127 |
2,007 |
1,739 |
|
Client-initiated |
386 |
122 |
182 |
212 |
224 |
|
Other |
1 |
0 |
0 |
0 |
0 |
|
Total cases resolved |
813 |
535 |
1,309 |
2,219 |
1,963 |
Note: GST Performance Agreement Schedule A 7b.
|
Type of measure |
2020–21 |
2021–22 |
2022–23 |
2023–24 |
2024–25 |
|---|---|---|---|---|---|
|
Proportion of objections to new Part IVC litigation cases |
49 |
88 |
41 |
28 |
34 |
Note: GST Performance Agreement Schedule A 7f.
Litigation
This year’s GST litigation results evidence our ongoing commitment to ensuring only appropriate cases proceed to a court or tribunal hearing. In 2024–25, only a small portion of all resolved cases proceeded to a hearing. Of these cases, Table 6.7 shows that 87% were decided as fully or partly favourable to the Commissioner.
There were 127 current Part IVC litigation cases on hand as of 30 June 2025, up from 106 cases on hand on 30 June 2024. Cases involving property, refund integrity and evasion issues continue to make up approximately 70% of total litigation cases on hand.
|
Decision outcome |
2020–21 |
2021–22 |
2022–23 |
2023–24 |
2024–25 |
|---|---|---|---|---|---|
|
Wholly supports ATO position |
55 |
67 |
85 |
60 |
74 |
|
Partially supports ATO position |
9 |
11 |
0 |
30 |
13 |
|
Wholly supports taxpayer position |
36 |
22 |
15 |
10 |
13 |
Note: GST Performance Agreement Schedule A 7g.
|
Case type |
2020–21 |
2021–22 |
2022–23 |
2023–24 |
2024–25 |
|---|---|---|---|---|---|
|
First instance |
41 |
47 |
58 |
62 |
66 |
|
Appeal |
4 |
5 |
1 |
5 |
1 |
|
Administrative matter |
0 |
0 |
1 |
0 |
1 |
Note: GST Performance Agreement Schedule A 7d. Part IVC First Instance cases are where the taxpayer lodges an Administrative Review Tribunal or Federal Court application when dissatisfied with the Commissioner’s objection decision.
|
Case type |
2020–21 |
2021–22 |
2022–23 |
2023–24 |
2024–25 |
|---|---|---|---|---|---|
|
First instance |
45 |
59 |
35 |
65 |
46 |
|
Appeal |
5 |
4 |
2 |
3 |
2 |
|
Administrative matter |
2 |
0 |
0 |
0 |
1 |
Note: GST Performance Agreement Schedule A 7e.
This year’s resolved cases that did not proceed to a hearing saw an increase in both settled and conceded by the Commissioner outcomes. Those withdrawn by the taxpayer or dismissed by the court or tribunal, decreased.
Since the mid-year report, there have been no strategic litigation case decisions (that is, cases with significant revenue or compliance risk, media attention or significant law clarification opportunities).
|
Outcome |
2020–21 |
2021–22 |
2022–23 |
2023–24 |
2024–25 |
|---|---|---|---|---|---|
|
Settled |
49 |
4 |
18 |
25 |
29 |
|
Conceded (whole or in part) |
22 |
13 |
11 |
27 |
32 |
|
Withdrawn by taxpayer |
22 |
36 |
53 |
27 |
24 |
|
Dismissed by courts or tribunals |
7 |
7 |
18 |
21 |
15 |
Note: GST Performance Agreement Schedule A 7h.