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ATO consultation report

Monthly report on ATO consultation activities.

Last updated 4 December 2025

About the ATO consultation report

This report describes ATO consultation activities in November 2025.

It contains:

Consultation matters

Statistics

Consultation matters received

1

Consultation matters completed

1

Matters under consultation

14

Advice and guidance products released for comment

5

Legislative instruments released for comment

2

Consultation matters received

[202524] s128F interest withholding tax exemption

[Consultation matters completed

[202523] Public Advice and Guidance priorities for Payday Super

Advice and guidance products released for comment

Draft Practical Compliance Guideline PCG 2025/D6 Apportionment of rental property deductions - ATO compliance approach

Draft Practical Compliance Guideline PCG 2025/D7 Application of section 26-50 of the Income Tax Assessment Act 1997 to holiday homes that you also rent out – ATO compliance approach

Draft Goods and Services Tax Ruling GSTR 2012/6DC Goods and services tax: commercial residential premises

Draft Taxation Determination TD 2025/D3 Income tax: when does a private or public ancillary fund ‘provide’ a ‘benefit’?

Draft Taxation Ruling TR 2025/D1 Income tax: rental property income and deductions for individuals who are not in business

Legislative instruments released for comment

Draft Legislative Instruments

Draft Legislative Instrument A New Tax System (Wine Equalisation Tax) (New Zealand Producer Rebate Claim Lodgment) Determination 2026

Draft Legislative Instrument Taxation Administration (PAYG Withholding Variation for Company Directors and Certain Office Holders) Legislative Instrument 2026

Draft Explanatory Statements

Draft Explanatory Statement A New Tax System (Wine Equalisation Tax) (New Zealand Producer Rebate Claim Lodgment) Determination 2026

Draft Explanatory Statement Taxation Administration (PAYG Withholding Variation for Company Directors and Certain Office Holders) Legislative Instrument 2026

See open consultation for products open for comment.

News

Stewardship groups

The GST Stewardship Group met and the topics discussed included:

  • examination of the fraud environment
  • ATO app security features
  • Australian Banking Association update
  • small business digitalised tax experience and the resilience framework
  • supplementary annual GST return
  • a presentation from the Australian Border Force on their role in GST administration
  • legislation and ATO updates
  • recognition and reflection on 25 years of GST from Commissioner Rob Heferen and former Commissioner Michael D’Ascenzo

Members also participated in an out of session consultation meeting on draft public guidance for GST and build-to-rent residential property developments.

The Individuals Stewardship Group met and the topics discussed included:

  • vulnerability capability
  • taxpayer relief provisions
  • insights from ATO Commissioner Rob Heferen.

The Large Business Stewardship Group met and the topics discussed included:

  • Payday Super for employers
  • the ATO’s work on productivity reform
  • the Corporate Tax Associations ‘Provide it once’ survey results
  • GST Top 100 program changes consultation outcomes
  • public country-by-country reporting
  • 2026 Reportable Tax Position Schedule changes
  • release of the ATO’s transparency reports
  • Treasury and Board of Taxation updates.

The Not-for-profit Stewardship Group met and the topics discussed included:

  • The evolving landscape informed by the lodgment of the not-for-profit (NFP) self-review return, and population shifts observed in the tax position of self-assessing, taxable and charitable NFPs.
  • Public guidance forward program, including overview of draft tax determination TD 2025/D3 Income tax: when does an ancillary fund provide a benefit?
  • new measures and shaping future NFP tax administration including
    • introduction of DGR class for community charity endorsement and annual reporting
    • doubling philanthropic giving reforms
  • Payday Super and compliance approach
  • 2026 compliance program view
    • emerging NFP concession risks and program overview
    • GST insights and treatment strategies to address GST risks.

The Private Groups Stewardship Group met and the topics discussed included:

  • the ATO annual report
  • Corporate tax transparency report
  • R&D tax incentive transparency report 2022–23
  • Next 5,000 program, Medium and emerging program and Top 500 program
  • Payday Super
  • ATO regulatory reform initiatives
  • Recent public advice and guidance and
  • Recent litigation.

The Small Business Stewardship Group met and the topics discussed included:

  • Australian Chamber of Commerce and Industry's ‘Future Makers’ women in small business
  • the ATO’s 2025–26 payment strategy
  • small business tax gap
  • Payday Super
  • small business litigation funding changes.

The Superannuation Industry Stewardship Group (SISG) met and the topics discussed included:

  • updates from regulators
  • environmental scan of industry trends and member perspectives
  • high-risk super switching and regulatory responses
  • fraud and cyber security, including ecosystem response simulations
  • insights from the ATO Commissioner and discussion on industry priorities
  • ATO’s Vulnerability Framework
  • review of 2025 SISG achievements and 2026 priorities.

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