Engaging with large corporates − 2025 insights

What we've learned from the public groups findings reports as of 30 June 2025.

Last updated 18 September 2025

How we develop our insights

We have a dedicated workforce monitoring, reviewing, assuring and engaging with the largest public and multinational groups in Australia.

Annually, we publish the results from our key programs with public and multinational businesses. We understand there is interest in the ATO being transparent about the outcomes of our programs and whether we are effective at monitoring and improving tax compliance of large businesses.

These results and insights are contained in the following reports:

Positive behaviours from continued cooperative and close engagement

This year, we continue to see an incremental increase in large businesses obtaining overall high assurance ratings for both income tax and GST giving us confidence that most large businesses are meeting their tax obligations. Specifically:

64% of top 100 taxpayers (from 59% in 2024) for income tax and 38% of top 100 GST reporters (from 30% in 2024) for GST
29% of top 1,000 taxpayers (from 27% in 2024) for income tax and 41% of top 1000 GST reporters (from 37% in 2024) for GST.

For the top 100 and top 1,000 taxpayers who haven’t achieved high assurance, majority achieved medium assurance in 2025.

These assurance ratings give us high levels of confidence over taxes paid and losses generated or utilised by taxpayers in these programs.

For income tax, of the $55.5 billion and $32.8 billion paid by top 100 and top 1000 taxpayers respectively around 88% and 94% was paid by taxpayers that had achieved medium or high assurance.
GST showed even higher levels of assurance across GST paid. Of the $11.1 billion and $12.1 billion GST reported and paid by top 100 and 1000 taxpayers respectively, nearly 100% is attributable to taxpayers that have achieved high or medium assurance.

Recurring engagement with public and multinational businesses, provides tax certainty for both us and the taxpayer. Businesses also regularly request our advice to understand how the law applies before lodging their return or undertaking a transaction, with over 80% of requests resulting in a favourable outcome.

With increasing cross-border dealings, minimisation of double tax exposure is an increasing objective for many taxpayers. We continue to prioritise our advance pricing arrangement (APA) program and are recognised internationally as having a robust program. We would like to continue to see this grow for the right arrangements with a focus on bilateral APAs.

Engagement informs insights and supports revenue collection

We use the Reportable tax payable (RTP) schedule to gain oversight of key corporate tax risks relating to public and multinational businesses. The number of disclosures has increased by over 50% over the 4 years from 2021 to 2024 with the number of schedules lodged increasing by 21% over the same period. This is the result of the expansion of lodgment requirements and more taxpayers meeting the eligibility criteria for completion of the schedule.

Overall, the data from the RTP schedule indicates high levels of voluntary compliance by the reporting population. In relation to disclosures for 2024–25, we have observed an increase in low risk disclosures and a decrease or no change in the proportion of high risk disclosures across the various questions.

We will provide updated insights on public and multinational business disputes and outcomes in the coming weeks.

Key highlights will show, in 2024–25, we:

raised $4.11 billion in total liabilities, made up of $2.62 billion in tax liabilities, $331 million in interest and $1.16 billion in penalties
collected an additional $2.2 billion voluntarily, in response to our preventive compliance interventions.

Global profit shifting continues to be a major focus in disputes with these businesses. This is reflective of the prevalence of these arrangements reported in the RTP schedule.

Aligned with large corporate transparency

Our insights into public and multinational businesses support what we see across other reports, such as Corporate tax transparency and Large corporate groups income tax gap.

While we are confident most public and multinational businesses continue to pay the right amount of tax, it’s important we maintain engagement and assurance with these taxpayers.

We regularly review our processes, assurance programs and guidance to continue to support public and multinational businesses to meet their tax obligations. In 2024–25, we:

reprioritised our engagement with top 100 taxpayers to ensure our Justified Trust engagements are in real time and that transactions and business changes are disclosed and considered closer to the time they occur, providing greater certainty for taxpayers and the ATO
introduced a differentiated approach to assuring top 1,000 taxpayers, based on factors such as their size and levels of assurance they’ve already attained
introduced the Supplementary Annual GST Return for top 100 and top 1000 taxpayers, enabling us to better tailor our engagements with these taxpayers
added new questions to the RTP schedule to monitor intangible migration arrangements
updated the APA program with recommendations from our review.

When we can, we are transparent about our approach to collecting revenue and delivering results to the Australian community through our settlements. However, the details of specific settlements are covered by confidentiality provisions and the tax secrecy requirements of the taxation law.

We encourage large public and multinational businesses to publicly disclose when they enter settlements with us. In some cases, we will also issue a media statement following a public disclosure of a settlement.

Over time our data indicates that specific issues identified in previous dealings are being resolved, correlating with a continuing trend towards improved behaviours, better outcomes and higher compliance.

QC103025