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  • Top 1,000 Tax Performance Program

    This program aims to obtain additional evidence to achieve greater assurance the largest 1,000 public and multinational companies and superannuation funds are reporting the right amount of income tax. This supports and expands existing compliance approaches, further enhancing our level of confidence in these taxpayers.

    Under the program, specialist tax performance teams engage with each taxpayer using tailored compliance approaches to assure they are reporting the right amount of income tax or identify areas of tax risk for further action.

    This program is part of the Tax Avoidance Taskforce announced by the Australian Government in the 2016–17 Federal Budget.

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    Who is covered by this program

    The program covers large public and multinational companies, focusing on the income tax affairs of taxpayers with turnover above $250 million.

    Taxpayers that continuously engage with us through pre-lodgment compliance reviews or have annual compliance arrangements are excluded from the Top 1,000 program. These taxpayers form part of our Top 100 program covering the largest taxpayers.

    How we tailor our compliance approach

    We obtain assurance or identify areas of tax risk by engaging with the taxpayer through a four-month streamlined assurance review.

    We will consider recent compliance activities when determining the timing and order of priority in selecting taxpayers under the program.

    We will notify the taxpayer before we commence a streamlined assurance review. We will provide a short period of time for the taxpayer to consider whether to make a voluntary disclosure of any tax concerns.

    We apply our justified trust methodology and tailor our compliance activities to the particular circumstances of the taxpayer in conducting each review. This includes:

    • the taxpayer’s overall tax performance
    • the type and size of business activities
    • tax risk management and governance
    • cooperation during the review.

    In a streamlined assurance review we seek to obtain assurance that:

    • appropriate tax risk and governance frameworks exist and are applied in practice
    • none of the specific tax risks we have flagged to the market are present
    • the tax outcomes of atypical, new or large transactions are appropriate
    • any misalignment between tax and accounting results is explainable and appropriate and the right amount of tax on profit from Australia-linked business is being recognised in Australia.

    A streamlined assurance review will focus on four income years.

    What to expect following a review

    Following a streamlined assurance review we will share our findings with you, including:

    • discussing the areas where we have assurance you reported the right amount of income tax
    • any identified tax risks.

    We may recommend specific actions to obtain greater assurance in particular areas, and may follow up on these recommendations.

    If we identify concerns or areas of tax risk, we will engage with you through a variety of tailored approaches. Generally we will seek to work with you collaboratively to obtain greater assurance or address identified concerns or tax risks. There will be circumstances where we will move to more intensive approaches, such as audits.

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    Findings report

    Our Findings Report Top 1,000 Tax Performance Program (income tax) March 2019 covers our key findings from over 280 streamlined assurance reviews.

    The report will help you understand how we apply the justified trust methodology to obtain greater assurance that large public and multinational taxpayers are paying the right amount of income tax or identify areas of tax risk for further action.

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    More information

    To learn more about the Top 1,000 program, email us at Top1000Program@ato.gov.au

    Last modified: 09 Jul 2019QC 52475