Top 500 key findings
In the 2024–25 financial year, through the Top 500 program, we continued to gain greater confidence that Top 500 groups are engaged in the tax system, complying with their tax obligations and paying the right amount of tax. The vast majority demonstrate strong compliance and transparency. Most issues identified that lead to additional liabilities relate to basic, preventable errors rather than deliberate non-compliance.
We saw more groups investing in tax governance frameworks and making improvements in tax governance. There was an overall 20% increase in the number of groups achieving justified trust or provisional justified trust, reflecting ongoing progress in Top 500 groups meeting the standards for high assurance and effective tax governance.
We are encouraged by more groups investing in tax governance and recommend that all Top 500 groups focus on their tax governance frameworks. This is the best way to ensure you are adopting the correct tax treatment and preventing errors from being made.
In the 2024–25 financial year, we saw some Top 500 groups making similar types of errors, such as omitting income, over-claiming deductions and other incorrect reporting, we have seen in past years. In addition, some of the same groups that made errors in earlier financial years made them again in 2024–25. Importantly, over three-quarters of the additional tax liabilities we raised in the 2024–25 financial year from Top 500 groups stemmed from basic errors we have seen and shared with Top 500 groups in earlier iterations of this findings report. This highlights the critical role of effective tax governance in preventing avoidable costs by getting it right in the first place.
Changes to the program in 2024–25
In April 2025, we refined the Top 500 program to focus our resources on groups with significant wealth. Key changes included:
- Groups previously included solely due to high turnover are now eligible to exit (subject to meeting exit requirements) or may remain if they achieve justified trust within 12 months.
- Certain fully tax-assured groups may access a streamlined assurance approach.
- The provisional justified trust pathway, previously limited to groups with predominantly passive income, is now available to all Top 500 groups.
Further details on these changes are covered in our Private groups – Business bulletin article and at Top 500 private groups tax performance program.
Program outcomes
In the 2024–25 financial year, we continued to gain greater confidence that many Top 500 groups are paying the right amount of tax. We assured income tax paid by Top 500 group entities totalling $835.11 million. This result encompasses assurance activities relating to the 2018 to 2024 financial years. We have now assured $15.47 billion in income tax over the life of the Top 500 program.
As of 30 June 2025, 36 private groups were in justified trust and 5 private groups were in provisional justified trust. These groups obtained full tax assurance, demonstrating that they are paying the right amount of tax. With their tax governance framework also in place, we have confidence they will continue to pay the right amount of tax moving forward.
We found that some Top 500 groups had applied incorrect tax treatments, which we corrected. This resulted in the following liabilities raised and payments collected during 2024–25:
- Raised income tax liabilities of $388.5 million (including $23.3 million from voluntary disclosures)
- Collected payments of $153.9 million from liabilities raised in the 2024–25 financial year and earlier.
Most groups that incurred liabilities and made voluntary disclosures had little or no tax governance in place. Following the April 2025 changes, the additional capacity created by a reduced number of Top 500 groups will be redirected to those with inadequate tax governance, as they present a higher risk of making errors.
Looking ahead to 2026
In the 2025–26 financial year, the Top 500 program will focus on progressing assurance activities for private groups eligible to exit following the April 2025 changes, with most exits anticipated during the year. Top 500 groups that are undergoing compliance action, such as current reviews or audits, are not eligible to exit until the matters are resolved. Groups that are eligible to exit the population have been given the option to remain in the Top 500 program provided they achieve justified trust within 12 months. Notably, several groups eligible to exit have chosen to remain in the program – many having invested in tax governance and experienced the benefits of justified trust.
Key priorities for the Top 500 program through 2025–26 will be to:
- Review our tax governance guidance and develop new tools for groups to self-assess tax governance. This will support groups in developing and embedding effective tax governance to reduce the risk of errors, improve compliance, and help groups to achieve justified trust.
- Continue identifying and reviewing all significant, atypical transactions through the Top 500 and Commercial deals programs, ensuring these transactions are consistently subject to thorough review and tax assurance.
- Direct additional resources to bring engagements up to date, being the last year lodged. With fewer Top 500 groups in the program after the groups exit, we will allocate more staff to Top 500 engagements and seek to expedite the assurance process. Groups that have not yet invested in governance, or are not fully assured, will be a priority to ensure that compliance issues are identified and addressed promptly.
- Commence engagements with new Top 500 groups. We have identified several groups that have grown significantly in wealth and turnover, leading to their inclusion in the Top 500 population. In 2025–26, we’ll engage with these new entrants to make sure they’re meeting their tax obligations and continue to do so as they grow.
As the wealthiest private groups in Australia, Top 500 groups have the resources to ensure that they lodge and pay their tax on time. This is our expectation and the expectation of the government and broader Australian community.
In 2025–26, we will focus on ensuring all entities in a Top 500 group have up-to-date lodgments, including information returns such as those for trusts and partnerships. For those that don't lodge on time, we will undertake firmer action such as issuing default assessments, imposing penalties, taking prosecution action and issuing media releases on successful prosecution outcomes. This will ensure that we meet the community’s expectation that groups lodge on time.
Top 500 groups will need to review their group structures, take prompt corrective action if necessary, and ensure all their lodgment obligations remain up to date. There will also be an expectation that any outstanding payments due are made or payment plans are put in place.