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ATO consultation report

Monthly report on ATO consultation activities.

Last updated 8 September 2025

About the ATO consultation report

This report describes ATO consultation activities in August 2025.

It contains:

Consultation matters

Statistics

Consultation matters received

2

Consultation matters completed

1

Matters under consultation

9

Advice and guidance products released for comment

1

Legislative instruments released for comment

1

Consultation matters received

[202515] Public country-by-country report lodgment instruction

[202514] The ATO’s approach to taxpayer relief provisions

Consultation matters completed

[202509] GloBE rules – ‘non-profit organisation’ exclusion

[202505] Ordinary time earnings guidance review

Advice and guidance products released for comment

Draft Practical Compliance Guideline

PCG 2025/D4 Low-risk payments relating to software arrangements – ATO compliance approach

Legislative instruments released for comment

Draft Legislative Instrument

Draft Legislative Instrument Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return and Australian DMT tax return) Determination 2025

Draft Explanatory Statement

Draft Explanatory Statement Taxation Administration (Exemptions from Requirement to Lodge Australian IIR/UTPR tax return and Australian DMT tax return) Determination 2025

See open consultation for products open for comment.

News

Stewardship groups

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

  • the ATO’s international related party dealings statistics
  • form consultation process for the International dealings schedule and Reportable tax position schedule
  • large corporate compliance costs
  • thin capitalisation measures
  • feedback on the following public advice and guidance items
    • Practical Compliance Guideline PCG 2025/D3 Global and domestic minimum tax lodgment obligations – transitional approach
    • Law Administration Practice Statement PS LA 2004/14 ATO access to advice for corporate board on tax compliance risk
  • updates from Treasury and the Board of Taxation.

The National Tax Liaison Group met and the topics discussed included:

  • ATO productivity improvements
  • potential development of a cost of compliance framework
  • Better Targeted Superannuation Concessions (Division 296)
  • changes to small business litigation funding and test case funding program arrangements
  • the review of the ATO’s concessional arrangements.

The Tax Practitioner Stewardship Group met out of session on 3 occasions during August 2025 and the topics discussed included:

  • Tax Time 2025 focus items
  • the approach to improve the visibility of debts previously placed on hold and the impact this will have on agents and taxpayers
  • the Agent authorisation process for individuals and sole traders (Client-to-agent linking).

QC43732