Group updates
The group welcomed Michelle Sams as the new ATO co-chair following Rebecca Saint's move to the Litigation and Legal Services area and new members from Rio Tinto and the Tax Institute Australia. Several departing members were acknowledged and thanked for their contributions to the group during their tenure.
The ATO highlighted the release of several findings reports in October as well as the latest Corporate tax transparency report 2023–24 and Australian tax gap – overview data. We have also recently published the three-tier model for public and multinational businesses, which is a new framework for how we think about the way behaviours drive tax performance and non-performance across the system.
Co-chair Steve Southon commented that compliance costs for large corporates continues to be a key concern for members and referenced the 3 agenda items to be discussed on this topic, Board of Taxation update, productivity reform and 'Provide It Once' Corporate Tax Association (CTA) survey results.
Members recommended a future agenda item on the use of AI and automation in tax functions.
Payday Super
The ATO gave an overview of the Payday Super changes that were recently legislated and will take effect from 1 July 2026. The steps we are taking to ensure a smooth transition to Payday Super were explained, including the improvements to SuperStream and internal systems to identify and engage early with employers not making contributions.
Members discussed the types of system changes that may be required to support superannuation payments on payday and the proposed ATO compliance approach as outlined in Draft Practical Compliance Guideline PCG 2025/D5 Payday Super – first year ATO compliance approach. Members noted the benefits of a widespread marketing and communication approach reaching individuals and businesses, including how individuals should engage with their employers early to support business processes for Payday Super.
Board of Taxation
An overview of the Red Tape Reduction Review that commenced in September was delivered. The review is focused on business tax and linked to the broader government initiative of boosting productivity, though it is not intended to be about large-scale tax reform.
The Board of Taxation has released a consultation guide and led consultation sessions with a broad range of stakeholders, including:
- large, medium and small business
- advisers
- industry and professional associations
- digital service providers
- academics.
General themes from these sessions include an observed increase in reporting requirements, duplicative reporting of data within and across government departments, and treatment and reporting of fringe benefits tax. Members were encouraged to provide feedback to the board with written submissions remaining open until mid-December.
Members discussed potential opportunities to improve the process for reporting changes, including wholesale consideration of what is already being reported when implementing new forms or reporting requirements.
Productivity reform
The ATO provided an overview of the regulatory reform work that is underway to identify material and sustainable actions that could be taken to boost productivity, strengthen economic resilience and improve budget stability, such as leveraging natural business systems for tax administration purposes.
The ATO outlined a number of key initiatives and improvements already being implemented, considerations into how some may be expanded into other markets and how further improvements can be made to streamline and simplify tax businesses through their natural systems. Acknowledging the earlier discussion on reducing red tape, members discussed the costs business incur in providing information to the ATO during engagements and advised that savings could be achieved by removing some reporting requirements and increased transparency by the ATO on how information is used.
'Provide it once' CTA survey results
In response to an action item from a previous meeting, members led a discussion on the results from the CTAs recent 'Provide it once' survey, which highlighted 4 key themes regarding the views of large businesses with respect to reporting obligations:
- An observed differentiation in compliance approaches adopted by the ATO for taxpayers that have achieved high assurance, with no differentiated reporting obligations.
- A lack of clarity and understanding of why certain information is requested by the ATO, how it is used and why certain information may be sought more than once when previously provided in a different format.
- There is a widely held view that there is level of duplication of information required across certain forms and schedules, notably between the international dealings schedule, the reportable tax position (RTP) schedule, short form local file, and transfer pricing documentation.
- Businesses may be required to provide the same information to more than one government agency.
The ATO emphasised the importance of structured data in ATO systems to support a range of functions and business processes and acknowledged that this could be better communicated to the market. The co-chairs committed to meeting out-of-session to discuss practical next steps before returning to the group in 2026.
GST Top 100 program changes – outcomes from consultation
An overview on the outcomes from consultation on the changes to the GST Top 100 program for taxpayers that have achieved overall high assurance was provided. Limited feedback was received during consultation, and the changes are now being implemented in the program. More information on future engagement approaches is outlined in our Future GST engagement after initial GST assurance review guidance.
Public country-by-country reporting regime
Consultation on the Practice Statement Law Administration and the draft lodgment instructions is underway. Members discussed the early engagement process for seeking exemptions and queried what the data would look like when published. A future agenda item will be added for the ATO to provide further updates including outcomes from consultation.
Treasury
Treasury provided updates on:
- the implementation of Pillar Two
- preparing the next intergenerational report
- public consultation on the News Bargaining Incentive.
Members sought an update on the progress of unenacted measures and impacts from recent Federal Court decisions.
2026 reportable tax position schedule
The ATO provided an update on changes to a range of questions for the 2026 RTP. Several questions have been updated for clarity and members provided feedback on potential improvements to the schedule instructions.
Transparency reports
Members were updated with key observations and highlights from this year's suite of findings reports including:
- Top 100 – Income Tax and GST program
- Top 1,000 – Income Tax and GST assurance programs
- RTP – public and multinational businesses
- public and multinational businesses disputes and outcomes
- public and multinational businesses tax certainty programs.
Transition from SIGBOX to Kiteworks
The ATO provided an update on the transition to a new secure file transfer system. All new information requests will be issued using Kiteworks. Members provided feedback on functionality in Kiteworks.
Other business
The ATO provided an update on the notification process for changes to the international dealings schedule based on feedback from members at a previous meeting.
Attendees
|
Organisation |
Member |
|---|---|
|
ATO |
Michelle Sams (Co-chair), Public Groups |
|
ATO |
Fiona Knight, Public Groups |
|
ATO |
Michael Ingersoll, Public Groups |
|
Australian Energy Producers |
Michael Fenner |
|
Australian Retirement Trust |
Ian Roberts |
|
BHP Billiton Limited |
Andrew Cornish |
|
Big 4 Representative |
Lynda Brumm |
|
BlueScope |
Irene Filippone |
|
Board of Taxation |
Paul Korganow |
|
Business Council of Australia |
Pero Stojanovski |
|
Corporate Tax Association |
Paul Suppree |
|
CPA Australia |
Jenny Wong |
|
Law Council of Australia |
Adrian Varrasso |
|
Microsoft |
Reagan Gruenthal |
|
Multiplex |
Angela Giunta |
|
National Australia Bank |
Steve Southon (Co-chair) |
|
Property Council of Australia |
Robert Ward |
|
Rio Tinto |
Jasmine Leonard |
|
Telstra |
Kelly Heezen |
|
Treasury |
Diane Brown |
|
Treasury |
Marty Robinson |
Guest attendees
Guest attendees list
|
Organisation |
Attendee |
|---|---|
|
ATO |
Hoa Wood, ATO Executive |
|
ATO |
Isaac Callaway, Public Groups |
|
ATO |
Jan Pfitzner, Public Groups |
|
ATO |
Nadia Alfonsi, ATO Executive |
|
ATO |
Usha Narain, Superannuation and Employer Obligations |
Apologies list
|
Organisation |
Member |
|---|---|
|
ATO |
Virginia Gogan, Public Groups |
|
Coles Group |
Adalene Pandeli |
|
ResMed |
Christian Chan |