Tax issues for consideration
The following table provides a list of tax issues requiring assurance that arise in relation to interest income derived by a Top 500 group from deposits with financial institutions, or from investments in traditional securities (such as government and corporate bonds).
The table also provides examples of processes and procedures that could be developed by the Top 500 group to demonstrate that they have effective tax governance in place when managing those tax issues.
The list of tax issues is not exhaustive and the processes and procedures for each Top 500 Private Group may differ depending on the commercial circumstances around which investment in interest bearing investments are carried out.
Tax issue |
Tax assurance considerations |
Tax governance considerations |
---|---|---|
Record keeping – source documents |
Good record keeping underpins our ability to assure that Top 500 groups are paying, and will continue to pay, the correct amount of tax. It is also a requirement under s262A. |
The tax governance policy of the group should include procedures for:
|
Completeness of interest income disclosures |
Has all interest income derived by the group been captured? |
The tax governance policy of the group should include procedures for:
|
Interest income is reported in the correct period |
Has interest income been reported in the correct income year? |
The tax governance policy of the group should include procedures for:
|
Characterisation and calculation of gains and losses on the disposal of traditional securities |
Have gains and losses on the disposal of traditional securities been correctly characterised and reported on revenue account? |
The tax governance policy of the group should include procedures for correctly calculating gains or losses on sale of traditional securities. |
Correct reporting |
Has the entity who derived the interest income or who made the gain or loss, reported correctly? |
The tax governance policy of the group should include procedures for:
|
Governance framework example
To help in developing a documented tax governance framework, we have prepared an example of guidance that could be easily evolved into a checklist that may help Top 500 groups with simple affairs in ensuring they are correctly reporting interest income (under principle 2 of the 7 principles of effective tax governance).
Passive investors with simple affairs – checklist
Group head: Mr John Simple
Entity name: Mr John Simple
Checklist: Interest income and sale of traditional securities
Year end: 30 June 2022
Item |
Activity |
Responsibility |
Purpose |
---|---|---|---|
1 |
Maintenance of a central repository for documentation concerning statements recording interest income. |
Bill Bookkeeper |
Good record keeping practices. |
2 |
At the end of each month back up electronic copies of documentation in the central repository to a plug-in hard drive, or memory stick. |
Bill Bookkeeper |
Ensure records of Mr Simple’s are not lost in the event primary information sources are compromised. |
Item |
Activity |
Responsibility |
Purpose |
---|---|---|---|
3 |
Financial institutions or other entities paying interest are notified of Mr Simple’s TFN and the bank account to pay interest. |
Bill Bookkeeper |
Remove TFN withholding risk. Ensure interest received into the correct bank account. |
4 |
The timing and amount of the interest income should be recorded in the Excel spreadsheet entitled 'interest income register', within 3 days of interest being received. Accumulated totals should be maintained within the spreadsheet. |
Bill Bookkeeper |
Ensuring Mr Simple’s interest income disclosure is complete and referable to the correct year of income. |
5 |
Reconcile cash interest payments deposited to investment bank account with interest income statements. |
Bill Bookkeeper |
Helping ensure Mr Simple’s interest income disclosure is complete. |
6 |
Before forwarding information to tax Agent, review spreadsheet, bank accounts and term deposit confirmations, to sense-check interest income has been captured and correctly recorded as expected. |
Bill Bookkeeper |
Helping ensure that Mr Simple’s interest income disclosure is complete. |
7 |
At least 4 weeks before the due date for lodgment of Mr Simple’s tax return, provide Mr Simple’s tax agent with:
|
Bill Bookkeeper |
Ensuring Mr Simple’s tax return is lodged on time. Helping the tax agent with the process of preparing Mr Simple’s tax return. |
Item |
Activity |
Responsibility |
Purpose |
---|---|---|---|
8 |
Tax agent to provide an annual engagement letter to Mr Simple that specifies the tax agents and Mr Simple’s responsibilities under the engagement. |
TAG & Mr Simple |
To provide clarity around:
|
Item |
Activity |
Responsibility |
Purpose |
---|---|---|---|
9 |
Logic check interest income calculations in Mr Simple’s interest income register spreadsheet. |
Tax agent |
Integrity check over primary data source from which interest income information is obtained. |
10 |
Retain and file working papers |
Tax agent |
Retention of records that support tax return disclosures. |
Item |
Activity |
Responsibility |
Purpose |
---|---|---|---|
11 |
Interest income received during the year is migrated across from the interest income register spreadsheet across to Mr Simple’s income tax return. |
Tax agent |
Correctly capture interest income in the return. |