Welcome
The group welcomed 6 new members and looks forward to the experience and contributions they will bring to the group.
This meeting's agenda continues to build upon the group's focus on the large market reporting compliance burden and includes several items to address specific issues raised by members.
ATO strategy
The ATO provided an overview of the draft ATO strategy that outlines our strategic direction towards 2030. It highlights key focus areas and strategic shifts that will position us to achieve our vision in the longer term. We are seeking feedback from a range of stewardship and key stakeholder groups.
Members provided comments on several aspects of the draft document including the language and terms used throughout, the purpose or intended audience of the document, and the overall design.
Board of Taxation
The Board of Taxation (BoT) provided an update on the Red Tape Reduction review that commenced in September 2025. Public consultation through written submissions and a series of roundtables has raised a lot of points for BoT to consider and based on the terms of reference.
Targeted consultation on specific matters has commenced. The report is due to the Treasurer by 30 June 2026.
The BoT has also recently commenced a 12-month statutory review on the operation of the new thin capitalisation rules, with the report due to the Treasurer by 20 January 2027. The terms of reference have been published on the BoT website. A consultation guide will be released in March. Written submissions will be sought with the BoT particularly interested in seeking examples from businesses on how the rules are being applied in practice.
Large market reporting
The ATO provided an update on an open action item to address 4 key themes regarding the views of large businesses with respect to reporting obligation compliance burden as discussed at the last meeting. A paper is being prepared to consolidate the underlying facts on large market reporting obligations, and to respond to feedback and comments which have been provided to the ATO and will be shared with members for feedback out-of-session. Members are encouraged to provide further specific examples of duplicative or onerous reporting for consideration.
International related party dealings statistics
An overview of the key insights from the International related party dealings statistics for 2023–24 published on 16 February 2026 was provided.
Public CBC reporting
Updated guidance on the Public country by country (CBC) reporting has been published. This includes the final instructions and approved form, guidance on a range of technical issues such as the types of entities that are required to report, and how to request an exemption. Members discussed the process for publishing public CBC data.
Pillar Two
An update on the implementation of the Pillar Two regime was provided with a focus on the domestic form and lodgment obligations.
The draft form has been released on ato.gov.au and first forms will be due 30 June 2026 for fiscal years ending before 31 December 2024.
Practical compliance guideline PCG 2025/4 Global and domestic minimum tax lodgment obligations – transitional approach has been released which outlines the ATO's transitional compliance approach during the Pillar Two transition period.
Other important Pillar Two developments include:
- the recent Organisation for Economic Co-operation and Development side-by-side announcement
- Australia becoming a signatory of the Multilateral Competent Authority Agreement on the exchange of global anti-base erosion rules (GloBE) information on 28 January 2026.
Payday Super
The ATO provided an overview of guidance and resources that have recently been published to support external readiness for Payday Super and noted upcoming communications and engagements.
Information was provided to address specific questions from members on:
- contractors being paid through accounts payable systems
- parental leave payments
- the Payday Super working group.
ATO systems
The ATO provided updates on the implementation of business improvement strategies for a range of service offerings and processes for large businesses based on feedback previously provided by members.
Compliance updates and emerging issues
The ATO provided updates on several matters including the:
- ongoing work on the s128F withholding tax exemption
- use of Artificial Intelligence
- recent changes to penalty and interest remission processes.
- publication of the goods and services
- tax determination for formula products.
- updates to the instructions for the international dealings schedule and local file, and reportable tax position schedule questions.
Treasury
Treasury provided updates on:
- current geopolitical pressures
- preparations for the upcoming Budget
- outcomes from the public consultation on the news bargaining incentive
- division 296
- Pillar Two implementation.
Attendees
|
Organisation |
Attendees |
|---|---|
|
ATO |
Michelle Sams (Co-chair), Public Groups |
|
ATO |
Fiona Knight, Public Groups |
|
ATO |
Lara Cavanough, Public Groups |
|
ATO |
Michael Ingersoll, Public Groups |
|
BHP Billiton Limited |
Andrew Cornish |
|
Big 4 Representative |
Alex Lamb |
|
Board of Taxation |
Paul Korganow |
|
Business Council of Australia |
Pero Stojanovski |
|
Chartered Accountants Australia and New Zealand |
Mark Bradford |
|
Coles |
Adalene Pandeli |
|
Corporate Tax Association |
Paul Suppree |
|
CPA Australia |
Jenny Wong |
|
Insurance Australia Group Limited |
Sarah Pang |
|
Law Council of Australia |
Judith Taylor |
|
Microsoft |
Reagan Gruenthal |
|
National Australia Bank |
Steve Southon (Co-chair) |
|
Origin Energy |
Catherine Feng |
|
Property Council of Australia |
Robert Ward |
|
ResMed |
Christian Chan |
|
Rio Tinto |
Jasmine Leonard |
|
Telstra |
Kelly Heezen |
|
Treasury |
Marty Robinson |
|
Uber |
Kelvin Ng |
Guest attendees
Guest attendees list
|
Organisation |
Attendee |
|---|---|
|
ATO |
Isaac Callaway, Public Groups |
|
ATO |
Jonathan Todd, International Support and Programs |
|
ATO |
Naomi Westwood, Superannuation and Employer Obligations |
|
ATO |
Sally Bird, Frontline Business Improvement |
|
ATO |
Stephanie Long, Public Groups |
|
ATO |
Tim Smith, International Support and Programs |
Apologies
|
Organisation |
Member |
|---|---|
|
Australian Energy Producers |
Michael Fenner |
|
Treasury |
Diane Brown |