Latest findings
The 2025 Top 100 income tax and GST assurance findings report shows:
- high levels of compliance of most of our largest taxpayers
- continued investment we make to maintain assurance over the tax affairs of top 100 taxpayers
- positive impact of the justified trust program on taxpayer behaviour and compliance.
We have recently refocussed 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.
Income tax
Key highlights for income tax:
- We continue to see high levels of assurance with most large business obtaining high assurance ratings
- We continue to see that most large businesses are meeting their tax obligations, with 83% of top 100 taxpayers maintaining either high or medium overall assurance ratings.
- The number of top 100 taxpayers attaining overall high assurance has increased to 64% (from 59% in 2024). This has led to a decrease in the number of top 100 taxpayers rated as medium assurance to 19% (a reduction from 23% in 2024).
- Of the $59.2 billion of income tax paid by Top 100 economic groups in 2023, $48.6 billion was reported by taxpayers that have achieved a high or medium assurance rating in their latest review.
- Around 31% of the Top 100 population did not pay tax in the 2023 year. This may be due to legitimate business reasons. For example, they may not have made a profit due to economic conditions or the life cycle of the project may not yet be income producing or they may be recouping prior year losses.
- 85% (22 of 26 taxpayers) of nil taxpayers have achieved high or medium assurance providing a high level of confidence about the tax affairs (including losses) of these taxpayers. Those taxpayers that have attained low assurance are subject to further review.
- Overall low assurance ratings have remained stable at 13%. Disputes and systemic risks continue to remain a feature of this population.
- We are reprioritising real time engagement, providing tax certainty pre-lodgment, reducing compliance costs for business and the ATO
- We have recently reprioritised our efforts on achieving real time engagement. The program has always been intended to work this way, given our focus on prevention before correction. However, our engagement has often been retrospective.
- More than 90% of top 100 taxpayers now have current year (real time) justified trust reviews underway, and over half of those have no past year justified trust reviews outstanding. We anticipate more than 80% of taxpayers will have no past year justified trust reviews by the end of 2025. However, a small number of these taxpayers may have other investigations in relation to specific matters underway, including audits.
- By ensuring our justified trust engagements are in real time and that transactions and business changes are disclosed and considered closer to the time they occur, we are able to provide greater tax certainty for taxpayers and the ATO.
- We continue to observe improvements in tax governance which gives us greater confidence that errors are reduced, and tax risk is appropriately managed
- Tax governance is a critical pillar of the justified trust methodology for large public and multinational businesses. We observed a notable increase in Stage 3 ratings from 35% in 2024 to 41% in 2025. This signifies enhanced tax control frameworks that are being ‘lived in practice’ and independently verified as operationally effective. These improvements give us greater confidence that errors are reduced, and tax risk is identified and managed by the organisation.
GST
Key highlights for GST:
- We continue to see high levels of assurance with most large business obtaining high or medium assurance ratings
- Of the top 100 GST reporters reviewed, 97% have obtained overall high or medium assurance ratings.
- A total of 38% of top 100 GST reporters obtained high assurance for GST (an increase from 30% in 2024) indicating that these taxpayers have paid the right amount of GST for the year reviewed. A total of 59% (a decrease from 63% in 2024) attained medium assurance.
- Overall low assurance ratings have remained stable at 2%.
- We continue to observe improvements in tax governance which gives us greater confidence that errors are reduced
- Over half of the top 100 GST reporters have obtained a Stage 2 or Stage 3 rating for tax governance. Stage 3 was achieved by 12% of GST reporters reviewed. This is important as errors due to poor governance and controls are the largest driver of amendments in the large market. Achieving stage 3 means that controls are in place to detect and remediate errors.
- Our reviews are encouraging improvements in correct reporting
- 95% of top 100 taxpayers have obtained a high or medium assurance rating for correct reporting. The number of taxpayers obtaining high assurance for correct reporting increased to 58% in 2025.
- GST corrections, including those amounts that were voluntary disclosures (VDs) processed in 2025 were typically not material in dollar terms relative to total GST reported and paid. However, in some cases the errors were large, and in a small number of cases, penalties were applied.
- Importantly, many GST reporters have implemented, or have documented plans to implement, improvements to their controls, processes, and procedures to prevent the reoccurrence of these errors.
- We continue to see voluntary disclosures made by taxpayers during an assurance review. Taxpayers should be continually reviewing their GST compliance for inadvertent errors or misreporting as part of their business as usual tax governance processes.
- We continue to see improvements in GAT ratings
- The GST analytical tool (GAT) is a useful tool for taxpayers to check how their various streams of economic activity are treated for GST purposes and have confidence in their GST outcomes. A Stage 2 or 3 rating was attained by 85% of taxpayers who had the GAT applied during an assurance review.
- Taxpayers are encouraged to embed the GAT as part of their own governance processes.
- With the introduction of the Supplementary annual GST return we expect to be able to undertake more targeted and less resource intensive GST reviews for many taxpayers
- We have introduced the Supplementary annual GST return (SAGR) from the 2024–25 financial year for large business that have had a GST assurance review. The SAGR will enhance our ability to monitor GST compliance and undertake more targeted and less resource intensive GST reviews for many taxpayers.