ATO logo

Methodology for estimating the PAYG withholding tax gap

Learn the method we use to estimate the pay as you go (PAYG) withholding gap.

Published 3 November 2025

What has changed

There have been no changes to our method this year. This is the second year of applying a bottom-up approach methodology based on the random enquiry program (REP) to inform gap estimate results.

Step 1: Estimate unreported PAYG withholdings

Unreported tax consists of the additional tax expected to be raised if we undertook compliance activity on the portion of the tax base not covered. It arises from incorrectly reported tax returns, as unreported withholdings, from the active employing entities population.

We use the REP compliance outcomes to determine the average amendment amount and average rate of amendments. These results are then extrapolated to the whole of the active employing entities to calculate the estimated unreported tax amount.

Step 2: Estimate non-detection

We account for non-detection by applying an uplift factor to amendments and hidden wages. The impact of non-detection on the PAYG withholding gap is estimated to be $5,607 million in 2022–23.

Not all errors are detected through the REP. We account for these by applying a non-detection uplift to the unreported tax liability estimate.

The 2 sources of non-detection for this tax gap relate to:

  • PAYG withholding misreporting
  • hidden wages.
Table 2: Source of non-detection in the PAYG withholding gap 2017–18 to 2022–23

Source of non-detection

2017–18
($m)

2018–19
($m)

2019–20
($m)

2020–21
($m)

2021–22
($m)

2022–23
($m)

PAYG withholding misreporting (excluding hidden wages)

188

197

208

263

259

306

Hidden wages

3,951

4,160

4,321

4,503

4,831

5,302

Total non-detection

4,139

4,357

4,530

4,766

5,090

5,607

 

Step 3: Estimate non-pursuable debt

We add estimated non-pursuable debt.

Step 4: Calculate the gross gap and net gap

We combine the amounts determined above for amendments, unreported tax, and non-detection with non-pursuable debt to obtain the gross and net tax gaps. The net gap is equal to the gross gap less amendments.

We then add the gross gap to the tax voluntarily paid amount to estimate the theoretical tax liability. We calculate the gap percentages by dividing the gap estimate by the theoretical tax liability.

Summary of the estimation process

Table 3 provides a summary of each step of the estimation process and the results for each year.

Table 3: Summary of estimation process (value) for PAYG withholding gap

Step

Description

2017–18

2018–19

2019–20

2020–21

2021–22

2022–23

1

Estimate unreported amounts and extrapolate to population ($m)

377

394

417

525

518

611

2

Apply estimate for non-detection ($m)

4,139

4,357

4,530

4,766

5,090

5,607

3

Estimate for non-pursuable debt ($m)

704

748

784

797

863

863

4.1

Gross gap ($m)

5,220

5,499

5,731

6,088

6,471

7,082

4.2

Subtract compliance outcomes ($m)

2,463

2,966

1,953

1,354

1,873

2,348

4.3

Net gap ($m)

2,757

2,533

3,778

4,734

4,598

4,734

4.4

Add expected collections ($m)

194,692

207,730

216,379

221,811

241,542

271,612

4.5

Theoretical liability ($m)

197,449

210,263

220,157

226,545

246,139

276,345

4.6

Gross gap (%)

2.6%

2.6%

2.6%

2.7%

2.6%

2.6%

4.7

Net gap (%)

1.4%

1.2%

1.7%

2.1%

1.9%

1.7%

Note: Non-detection is captured within the unreported tax component.

Find out more about our overall methodology, data sources and analysis used at Principles and approaches to measuring gapsExternal Link.

Limitations

The current methodology provides an aggregated estimate of the PAYG withholding gap.

The assumptions we use to construct our estimate are informed by actual data and expert opinion. The following caveats and limitations apply when interpreting this tax gap estimate:

  • The precision of the estimate is limited by the sample size – we use a bundled sample.
  • The true extent of non-detection is unknown and is challenging to measure. We assume there will be errors and omissions in our compliance activities due to factors outside our control and limitations in operational capability and capacity.
  • The true extent and distribution of hidden wages is challenging to measure. We assume that there is shadow economy behaviour, such as cash wages, in this population.

Updates and revisions to previous estimates

Each year we refresh our estimates in line with our annual report. Changes from previously published estimates occur for a variety of reasons, including:

  • improvements in methodology and assumptions
  • revisions to data
  • additional information becoming available.

Figure 2 displays the net gap estimates from our current model compared to the previous estimates.

Figure 2: Current and previous PAYG withholding gap estimates, 2008–09 to 2022–23

Our previous and current net gap estimates as outlined in Table 4.

Table 4: Current and previous PAYG withholding net gap estimates (percentage), 2017–18 to 2022–23

Year published

2017–18

2018–19

2019–20

2020–21

2021–22

2022–23

2025

1.40%

1.20%

1.70%

2.10%

1.90%

1.70%

2024

0.90%

0.50%

1.70%

2.00%

1.80%

n/a

2023

3.10%

2.60%

2.40%

1.70%

n/a

n/a

2022

2.60%

1.90%

1.50%

n/a

n/a

n/a

2021

1.80%

1.60%

n/a

n/a

n/a

n/a

2020

1.80%

n/a

n/a

n/a

n/a

n/a

 

QC105684