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Top 100 justified trust program

Applying justified trust to the top 100 population.

Last updated 12 October 2022

Applying justified trust to the top 100 population.

Justified trust is a concept from the Organisation for Economic Cooperation and Development (OECD).

We originally introduced the justified trust concept starting with the top 100 population in 2016.

We complete justified trust reviews as part of the yearly pre-lodgment compliance review (PCR) and annual compliance arrangement (ACA) processes.

In these reviews, we apply consistent rating categories to our overall level of assurance. We apply a high assurance rating where we have confidence that the taxpayer paid the right amount of tax for the period reviewed.

Due to the size and complexity of taxpayers in the top 100 population, we expect it may take some taxpayers several years to reach high assurance. We are working with each of the top 100 as part of the PCR and ACA processes to gain and maintain a high level of assurance. We will tailor future engagements to focus on new, unassured areas and changes.

Where a top 100 taxpayer attains an overall high level of assurance under our justified trust program, it means we have confidence that they have complied with Australian income tax laws.

In recognition of the level of trust we have in the reported tax outcomes of these taxpayers, we will tailor our future engagement approach to focus on maintaining our high level of confidence. This is known as the 'Monitoring and Maintenance' approachThis link opens in a new window. This approach will apply to taxpayers for the two income years following an overall high assurance outcome.

For Top 100 ACA taxpayers who have attained an overall high level of assurance, we will revert to an annual ACA review in accordance with the ACA terms of arrangement.

Top 100 Findings report

Our Findings report top 100 program (income tax and GST) June 2023 covers our key findings from tax assurance reviews completed to 30 June 2023.

These findings will help you understand how we apply the justified trust methodology to:

  • obtain greater assurance that Top 100 taxpayers are paying the right amount of income tax or GST, or
  • identify areas of tax risk for further action.

More information

To learn more about the Top 100 program, email us at