About the top 100 population
The top 100 population:
- consists of public and multinational businesses and Australian Prudential Regulation Authority (APRA) regulated superannuation funds that have substantial economic activity related to Australia
- consists of the largest contributors to corporate income tax, excise, and petroleum resource rent tax (PRRT) collections
- includes some of the largest remitters of GST.
The top 100 population is a significant contributor to total income tax collections. Based on 2023 income tax returns, top 100 economic groups paid about $59.2 billion or 42% of all corporate income tax.
We moderate the top 100 population annually having regard to several factors including the size of their Australian operations. We also review top 100 taxpayers annually and tailor our engagement based on the Action Differentiation Framework (ADF).
Note: In 2025 there were 83 economic groups in the top 100 population. This number varies year-on-year and some groups have more than one taxpayer in the top 100 population. Accordingly, the annual number of entities reviewed under the justified trust program does not equal 100.
Since the commencement of the justified trust program in 2016, our justified trust ratings have provided an objective mechanism for organisations to test and assess the effectiveness of their own tax governance processes as well as understand the organisation's tax profile. Publishing the findings report helps organisations understand how our assessment of their tax profile compares to peers in the market.
Top 100 taxpayers that have obtained overall high assurance ratings can achieve reduced compliance costs and are less likely to have intensive tax disputes with us. Taxpayers can also rely on our high assurance rating to mean that we will generally not apply compliance resources to those issues over which we have justified trust.
Owing to their significance in the tax system, we continually monitor top 100 taxpayers. However, we tailor the intensity of our reviews having regard to several factors including the level of assurance attained.
Where top 100 taxpayers achieve high assurance for income tax, we continue to monitor their disclosures and tax outcomes with a focus on significant new transactions and business changes. Similarly, for GST we generally take a monitoring stance to the GST affairs of top 100 reporters who attained overall high or medium assurance in an initial review. We also conduct some targeted engagement to address GST issues arising from the initial review for some taxpayers.
However, a justified trust rating is not ‘set and forget’. Every 4 years we conduct a tailored justified trust review to refresh our confidence in the taxpayer’s tax outcomes.
Over the last 18 months we have refocussed our engagement with the top 100 population to ensure our reviews are more in real time. The program has always been intended to work this way, given our focus on prevention before correction, however, our reviews have often been retrospective.
We currently have real time justified trust reviews in progress with over 90% of the top 100 population for income tax. Over half of those have no past year justified trust reviews outstanding. This number is set to increase to over 80% by the end of 2025.
We also continue to encourage taxpayers to engage early with us and to make disclosures when changes or events happen, that is, prior to lodging their return. Mutual engagement on matters will provide confidence to taxpayers and the ATO that the tax outcomes reported in the returns are appropriate, or conversely, there is an informed understanding of where there may be a difference of view. We encourage taxpayers to ensure that evidence supporting the tax treatment of significant transactions is readily available and provided to the ATO in a timely manner to support early resolution of issues.
We have released Top 100 Pre-lodgment disclosure framework guidance about our expectations of taxpayers and how we will engage on these matters, and set out mutual obligations for real-time disclosures by top 100 taxpayers.
Justified trust and transparency
Tax compliance is a focus among boards, investors, customers and consumers, suppliers, community groups and other stakeholders of how organisations contribute to the communities in which they operate. Many see this as an important component of environmental, social and governance (ESG) performance indicators.
Societal attitudes and expectations in Australia and globally are increasingly encouraging organisations to make more transparent and sustainable business decisions that can lead to long-term growth benefiting all stakeholders. There continues to be calls for organisations to be more transparent about their operations and tax contributions, and to demonstrate that they are participating fairly in the economy.
We have observed that our justified trust ratings are leveraged by organisations to demonstrate their community and ESG credentials as part of their broader social licence to operate. The objective principles used in the justified trust initiative also serve to enhance the community’s understanding about large market compliance and their ability to differentiate good corporate tax citizens from others. Although there remains a level of non-compliance by some in this population which we continue to robustly address, the overall level of compliance is very high and possibly much higher than the current broader community understanding. Sharing these ratings can help address this gap for those organisations which have achieved high assurance.
Our results to date demonstrate that most large businesses do and want to do the right thing. We have a high level of willing participation by most large corporate groups. This is shown by 83% of top 100 taxpayers having obtained either a high or medium overall assurance rating for income tax and 97% for GST. There are also examples of companies that have committed to long-term behavioural change, including restructuring, changing their business practices, and settling long-standing disputes with us.
We continue to see justified trust assurance ratings disclosed together with other contextual information to assist the community’s understanding of the tax contributions of the largest participants in the Australian economy. We encourage the continued adoption of tax transparency practices (including the disclosure of assurance ratings) which supports community confidence that the largest taxpayers are paying the right amount of tax.
Our approach
In 2016 we introduced the justified trust initiative starting with the income tax affairs of the top 100 population. In 2019 we expanded the initiative to include the GST affairs of the top 100 population.
We apply the justified trust methodology and seek to obtain assurance of 4 focus areas, that:
- Appropriate tax risk and governance frameworks exist and are applied in practice. This includes the design and operational effectiveness of business systems to create, capture and report transactions correctly for GST purposes.
- None of the specific income tax or GST risks we have flagged to the market are present.
- Tax outcomes of atypical, new, or large transactions are appropriate.
- We understand why the accounting and tax results vary. We analyse the various streams of economic activity and how they are treated for taxation purposes. We also analyse the sales, acquisitions, and other data, and compare this to net GST paid.
The justified trust program has reached maturity in relation to the assurance reviews of income tax and more recently GST affairs for top 100 taxpayers. Over the past few years, we've worked closely with the top 100 taxpayers and have detailed in their tax assurance reports (TARs):
- the criticality of a good, lived, tax governance framework and encouraging self-assessment against ATO 'better practices'
- the areas of their economic and tax affairs over which we have a high level of assurance
- areas where we have concerns or where improvements can be made and how a higher level of assurance can be obtained
- how the effective tax borne (ETB) on economic activities linked to Australia is critical to our understanding of their income tax risk profile (in particular, transfer pricing matters)
- our future engagement approach
- where a rating is provisional, how that issue resulting in the provisional rating has been addressed
- how the taxpayer has addressed governance gaps and ATO recommended enhancements, and other client next actions detailed in the TAR
- where the monitoring and maintenance approach is applied, whether we have been able to verify the tax outcomes from significant new transactions or significant changes to the taxpayer’s business activities.
The report outlines our findings for the 4 justified trust focus areas for income tax and GST, as well as our engagement approach once a top 100 taxpayer attains overall high assurance for income tax and for GST once high or medium assurance is obtained. We clearly set out the areas of concern and any planned compliance action, governance gaps and enhancements and how taxpayers can practically improve their assurance ratings. These reports are complemented by the annual ADF letters where we highlight to senior executives what is working well and any areas of concern requiring attention.
We have introduced the Supplementary annual GST return from the 2024–25 financial year for large business that have had a GST assurance review. The return covers:
- how recommendations, areas of low assurance or red flags outlined in the most recent GST assurance review (including subsequent interactions with us) have been actioned
- whether GST governance ratings have been maintained and if any material business or systems changes have occurred that impact on the GST control framework since the last GST assurance review
- the reconciliation between audited financial statements and annualised business activity statements
- whether any material uncertain GST positions have been taken in the period
- whether any material GST errors have been identified in the period and how these have been rectified, and whether any material amounts of credits have been claimed in the period that were referrable to earlier periods.
Our expectation is that the SAGR together with real-time disclosures will enhance our ability to monitor GST compliance and provide us with comprehensive and meaningful levels of detail to maintain assurance and undertake more targeted and less resource intensive reviews for many taxpayers. Where this is not the case our engagement is likely to be more intensive. We are currently consulting on how we will further streamline our engagement with high assurance GST taxpayers.