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Action Differentiation Framework

Find out about the ADF and how we approach engagement with public and multinational businesses.

Last updated 10 October 2021

How we engage with you

The way we engage with you is tailored or differentiated based on our understanding of the complexity of your affairs, informed by:

  • size
  • transparency of your engagement with us
  • choices and behaviours evidenced in your tax affairs
  • the level of risk you exhibit.

The ADF allows us to:

  • use resources efficiently, allocating them to priority focus areas and where specific attention is required
  • focus on the principles of obtaining justified trust.

Engagement frequency

Under the ADF, you are grouped into populations based on your total business income.

Population, total business income and our level of engagement


Total business income

Our level of engagement

Top 100

>$5b or market leader

Ongoing one-to-one tailored engagement:


Top 1000

$250m to $5b

Periodic one-to-one tailored engagement:



$10m to $250m

Periodic – may receive broader engagement, like campaign and nudge communications



Periodic – may receive broader engagement, like campaign and nudge communications

Engagement experience

The ADF guides how we tailor our engagement with you across a range of services and approaches based on the following:

  • Partnering
    • We partner with you to maintain good compliance.
    • If you are willing to engage and are transparent in maintaining compliance, we will partner with you to seek to deliver services in a timely and efficient manner to help you meet your tax obligations.
    • We will generally adopt a less intensive approach to our compliance interactions with you to maintain good compliance, reducing your compliance costs.
  • Encouraging
    • We encourage you to address our concerns.
    • If you take positions relating to complex arrangements giving rise to significant tax risks, you will be urged to address our concerns.
    • We will encourage you to improve our level of assurance over your affairs through the use of tailored services and approaches, according to your particular circumstances.
    • We'll also work with you to improve your future transparency and compliance.
  • Influencing
    • We take firm action to influence you to improve your compliance.
    • If you are generally not transparent and consistently take high risk positions, we'll adopt an intensive approach to ensure risks are addressed quickly.
    • The services and approaches we take will be tailored to your particular characteristics and behaviours.
    • We'll adopt firm approaches, like formal powers for information gathering, until you improve your transparency and compliance.

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