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Our three-tier model

Our three-tier model helps us understand key behaviours driving tax performance for PMBs.

Published 2 October 2025

We use the three-tier model (3TM) for public and multinational businesses to:

  • understand what behaviours drive tax performance and non-performance across the market and how they impact the large corporate tax gap
  • support us in making strategic decisions on what areas to focus on, including through population-wide approaches, to address risks and continue to support high levels of tax compliance by large corporates.

The model provides a holistic view of the tax and super systems in operation. Our focus is on:

  • supporting taxpayers in meeting their obligations
  • proactively monitoring and engaging with the market to
    • maintain high levels of compliance
    • prevent any deterioration in tax performance.

The model focuses on taxpayer behaviours, to help us understand which:

  • behaviours are more likely to contribute to increased tax performance
  • areas need more focus to ensure they are within check.

Our model for PMB entities helps us understand the tax system in operation and guide our areas of focus for compliance.

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