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Top 100 population

How we identify and categorise the top 100 and our engagement approach with this population.

Last updated 10 October 2021

The top 100 population consists of public and multinational businesses and super funds that have substantial economic activity related to Australia. They form the largest contributors to corporate income tax, excise, and petroleum resource rent tax (PRRT) collections. They are some of the largest remitters of goods and services tax (GST).

As the top 100 can have a significant effect on the health of our tax system, we engage with them one-to-one to manage their compliance.

How we identify and categorise the top 100

We make an assessment of each large public and multinational business at the economic group level. We consider an economic group to include all Australian-based entities under a direct or indirect Australian or foreign majority controlling interest.

We initially identify top 100 taxpayers based on the size of their Australian operations. Other factors we consider include income tax, GST, PRRT or excise paid and the influence the taxpayer may have on their market segment.

We apply an Action Differentiation Framework (ADF) to our top 100 taxpayers. This is based on a point-in-time assessment of a taxpayer's:

  • transparency in terms of their engagement with us
  • choices and behaviours as evidenced in their tax affairs
  • level of risk they exhibit.

Top 100 engagement approach

Our engagement with top 100 taxpayers is tailored or differentiated according to the ADF engagement approach. There are three ADF engagement experiences:

  • partnering
  • encouraging
  • influencing.

We use our professional judgment to make this assessment. The factors we consider in making our assessment vary for each tax product and by the information we have and the interactions we have with each taxpayer. We consider quantitative and qualitative measurements.

Top 100 taxpayers receive an annual letter from the Commissioner of Taxation advising them of how we will tailor our engagement with them across a range of services and approaches under the ADF. We clearly outline:

  • the engagement approach
  • the basis of our assessment
  • what this means for the taxpayer
  • how we intend to engage with them over the next 12 months.

We also give top 100 taxpayers additional detail about:

  • our concerns where we have finalised a justified trust review for income tax or GST
  • the areas of their economic and tax affairs over which we have assurance
  • our future engagement approach, which has been outlined in the annual tax assurance reports.

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