Ratings tables − Public and multinational business advice and guidance program

Table 1: Requests received and completed

Table 1 details the data used in Figure 1: Total requests received and completed 1 July 2021 to 30 June 2026.

Table 1: Total requests received and completed by year

Financial year	Received	Completed
2021–22	634	570
2022–23	446	511
2023–24	442	456
2024–25	481	478
2025–26	528	496

Table 2: Requests by product type

Table 2 details the data used in Figure 2: Requests received by product type – 1 July 2021 to 30 June 2026.

Table 2: Total requests received by product type, by year

Type of request	2021–22	2022–23	2023–24	2024–25	2025–26
Private rulings	314	196	258	257	240
Class rulings	106	68	66	62	100
Early engagement	143	106	74	98	85
Guidance and discretions	71	76	44	64	103

Table 3: A&G issues by 3TM risk

Tables 3.1 to 3.3 detail the data used in Figure 3: 2025–26 A&G issues by 3TM risk (Tier 1 and 2 only).

Table 3.1: A&G issues by 3TM risk – Tier 1 behaviour: Domestic tax positions and structures – 2025–26

Tier 2 event	Issues
Disposal of wholly domestic business structures	461
Treatment of distributions	405
Characterisation of business activities	236
Other domestic tax positions and structures	118
Total domestic tax positions and structures	1,220

Table 3.2: A&G issues by 3TM risk – Tier 1 behaviour: Cross-border investment structures – 2025–26

Tier 2 event	Issues
Structuring through vehicles or arrangements	73
Debt and capital structures	51
Other cross-border investment structures	46
Total cross-border investment structures	170

Table 3.3: A&G issues by 3TM risk – Tier 1 behaviour: Administrative compliance obligations – 2025–26

Tier 2 event	Issues
Employer and other indirect tax obligations	77
Other administrative	5
Total administrative compliance obligations	82

Table 4: Top 5 topics received

Table 4 details the data used in Figure 5: Requests received by top 5 topics – 1 July 2021 to 30 June 2026.

Table 4: Top 5 topics received, by year

Topic	2021–22	2022–23	2023–24	2024–25	2025–26
Withholding tax exemption	85	62	88	95	81
CGT	105	72	72	72	78
Capital management	114	75	63	67	73
Employee share schemes	74	53	63	61	60
International	29	40	13	40	45

Table 5: Request received by population type

Table 5 details the data used in Figure 6: Requests received by taxpayer population – 1 July 2021 to 30 June 2026.

Table 5: Request received by population type, by year

Population type	2021–22	2022–23	2023–24	2024–25	2025–26
Top 100	93	53	41	31	38
Top 1,000	128	97	81	90	109
Large risk	84	40	57	48	49
M&E risk	263	214	197	253	268
Outside ADF	66	42	66	59	64

Table 6: Requested received by advisor type

Table 6 details the data used in Figure 8: Requests received by advisor type – 1 July 2021 to 30 June 2026.

Table 6: Requests received by advisor type, by year

Advisor type	2021–22	2022–23	2023–24	2024–25	2025–26
Big 4 firm	343	214	228	209	231
Other firm	201	174	165	180	221
Taxpayer lodged	90	58	49	92	76

Table 7: Median total completion days

Table 7 details the data used in Figure 10: Median total days to complete request by product – 1 July 2021 to 30 June 2026.

Table 7: Median total completion days, by year

Product type	2021–22	2022–23	2023–24	2024–25	2025–26
Private rulings	142	160	148	142	150
Class rulings	173	197	189	177	146
Guidance and discretions	103	88	83	82	85
All products	151	148	148	142	142

Table 8: Difference from median total completed days

Table 8 details the data used in Figure 11: Requests completed in 2025–26 – difference from median total completed days by selected topic.

Table 8: Difference from median total completed days (142 days) by selected topic – 2025–26

Topic	Difference in days
Restructure	142
Deductions	133
International	54
Capital management	48
Managed investment trusts	26
CGT	5
Superannuation	4
Employee share schemes	−5
Withholding tax exemption	−31
Imputation	−63
Thin capitalisation	−85

Table 9: Average RFIs issued per topic

Table 9 details the data used in Figure 12: Average RFIs issued per topic – 2025–26.

Table 9: Average RFIs issued per topic

Topic	Number of RFIs
Restructure	3.3
Superannuation	2.4
Imputation	2.0
Employee share schemes	1.9
International	1.9
Capital management	1.8
Deductions	1.8
Average	1.7
CGT	1.6
Managed investment trusts	1.6
Withholding tax exemption	1.5
Thin capitalisation	1.3

Table 10: Median RFI response days and total completion days

Table 10 details the data used in Figure 13: Median RFI response days and median total completion days by selected topic – 1 July 2023 to 30 June 2026.

Table 10: Median RFI response days and median total completion days, by topic – 1 July 2023 to 30 June 2026

Topic	Median RFI response days	Median total completion days
Withholding tax exemption	42	112
Capital management	40	146
CGT	64	150
Superannuation	52	153
Employee share schemes	62	154
International	57	183
Restructure	103	194
Withholding taxes	175	224
Deductions	78	254
Managed investment trusts	49	259

Table 11: Outcome of class and private ruling request

Table 11 details the data used in Figure 14: Outcome of private ruling and class ruling requests – 1 July 2021 to 30 June 2026.

Table 11: Outcome of class and private ruling requests by year

Outcome	2021–22	2022–23	2023–24	2024–25	2025–26
Favourable (see note 1)	81%	78%	82%	80%	78%
No further action	13%	17%	13%	17%	17%
Decline to rule	4%	1%	2%	1%	2%
Unfavourable	2%	3%	3%	2%	3%

Note 1: The Favourable outcome category includes Part favourable and Neutral ruling outcomes.

Table 12: Outcome of class and private rulings by taxpayer population

Table 12 details the data used in Figure 15: Class and private ruling outcomes by taxpayer population 1 July 2021 – 30 June 2026.

Table 12: Outcome of class and private ruling by taxpayer population – 1 July 2021 to 30 June 2026

Outcome	Top 100	Top 1000	Large Risk	M&E Risk	Outside ADF
Favourable (see note 2)	89%	87%	78%	75%	80%
No further action	10%	9%	19%	18%	16%
Decline to rule	1%	1%	0%	3%	2%
Unfavourable	1%	3%	3%	3%	1%

Note 2: The Favourable outcome category includes Part favourable and Neutral ruling outcomes.

Table 13: Class and private ruling requests completed by engagement type and taxpayer population

Table 13 details the data used in in Figure 16: Class and private ruling requests completed following early engagement by taxpayer population – 1 July 2021 to 30 June 2026.

Table 13: Class and private ruling requests completed following early engagement by taxpayer population – 1 July 2021 to 30 June 2026

Population	From early engagement	No early engagement
Top 100	50%	50%
Top 1,000	40%	60%
Large risk	46%	54%
M&E risk	20%	80%
Outside ADF	15%	85%

Table 14: Early engagement requests by outcome

Table 14 details the data used in Figure 17: Outcome of early engagement requests – 1 July 2021 to 30 June 2026.

Table 14: Early engagement requests by outcome and year

Outcome	2021–22	2022–23	2023–24	2024–25	2025–26
Progressed to ruling	64%	69%	62%	56%	68%
Progressed to other product	5%	2%	4%	2%	1%
No further action	31%	29%	34%	42%	31%

Table 15: Pipeline of early engagement and direct ruling applications

Tables 15a to 15d detail the data used in Figure 18: Pipeline of early engagement and direct ruling applications through the A&G program – 1 July 2021 to 30 June 2026.

Table 15a: Early engagement requests – 1 July 2021 to 30 June 2026

Outcome of requests	Number of requests
Progressed to other product	17
No application lodged	180
Application lodged	352
Total early engagement requests received (see note 3)	549

Table 15b: Early engagement request applications – 1 July 2021 to 30 June 2026

Outcome of applications	Number of applications
No further action	25
Favourable ruling	272
Unfavourable ruling	6
Neutral ruling	7
Total post-early engagement rulings issued	285
Total early engagement request applications (see note 3)	352

Table 15c: Direct ruling applications – 1 July 2021 to 30 June 2026

Outcome of direct ruling applications	Number of applications
Decline to rule	30
No further action	212
Ruling issued	906
Total direct ruling applications received	1,148

Table 15d: Outcome of direct rulings issued – 1 July 2021 to 30 June 2026

Outcome of ruling	Number of rulings
Favourable ruling	835
Unfavourable ruling	37
Neutral ruling	34
Total direct application rulings issued	906

Note 3: These figures do not sum as some early engagement requests have resulted in ruling applications that are still in progress.

Table 16: Class and private ruling request outcomes by engagement type

Table 16 details the data used in Figures 19 and 20: Class and private ruling request outcomes with and without early engagement – 1 July 2021 to 30 June 2026.

Table 16: Class and private ruling request outcomes with and without early engagement – 1 July 2021 to 30 June 2026

Outcome	Requests with early engagement	Requests without early engagement
Favourable (see note 4)	90%	76%
Unfavourable ruling	1%	3%
Decline to rule	1%	3%
No further action	8%	18%

Note 4: The Favourable outcome category includes Part favourable and Neutral ruling outcomes.