Ratings tables − Public and multinational business advice and guidance program

Table 1 details the data used in Figure 1: Total requests received and completed 1 July 2020 to 30 June 2025.

Table 1: Total requests received and completed by year
Financial year	Received	Completed
2020–21	579	655
2021–22	634	569
2022–23	446	511
2023–24	439	453
2024–25	478	479

Table 2 details the data used in Figure 2: Requests received by product type 1 July 2020 to 30 June 2025.

Table 2: Total requests received by product type, by year
Type of request	2020–21	2021–22	2022–23	2023–24	2024–25
Private Rulings	314	314	196	258	258
Class Rulings	58	106	68	66	62
Early Engagement	153	143	106	74	97
Guidance and Discretions	54	71	76	41	61

Table 3 details the data used in Figure 3: Requests received by top 5 topics 1 July 2020 – 30 June 2025.

Table 3: Top 5 topics received, by year
Topic	2020–21	2021–22	2022–23	2023–24	2024–25
WHT Exemption	121	85	61	88	96
Capital Management	97	114	75	62	66
CGT	76	105	72	72	74
ESS	54	74	53	63	61
International	29	29	40	13	37

Table 4 details the data used in Figure 4: Requests received by taxpayer population 1 July 2020 – 30 June 2025.

Table 4: Request types received by population type, by year
Population type	2020–21	2021–22	2022–23	2023–24	2024–25
Top 100	77	93	53	41	31
Top 1000	116	129	97	81	92
Large Risk	58	83	40	56	42
M&E Risk	229	263	215	195	255
Outside ADF	99	66	41	66	58

Table 5 details the data used in Figure 5: Requests received by most recent income tax assurance review rating 1 July 2020 – 30 June 2025.

Table 5: Requests received by most recent income tax assurance rating
Assurance rating	2020–21	2021–22	2022–23	2023–24	2024–25
High assurance	91	108	63	45	48
Medium assurance	58	55	48	49	35
Low assurance	10	15	10	3	9
Not rated	420	456	325	342	386

Table 6 details the data used in Figure 7: Requests received by advisor type 1 July 2020 – 30 June 2025

Table 6: Products received by advisor type
Advisor type	2020–21	2021–22	2022–23	2023–24	2024–25
Big 4 firm	298	343	214	228	207
Other firm	193	202	174	164	182
Taxpayer lodged	88	90	58	47	89

Table 7 details the data used in Figure 9: Median total days to complete request by product 1 July 2020 – 30 June 2025.

Table 7: Median completion days
Product type	2020–21	2021–22	2022–23	2023–24	2024–25
Private rulings	148	141.5	159.5	147.5	142
Class rulings	203	173	197	189	177
Guidance and discretions	116	102	87.5	87	81
All products	150	148	147	148	142

Table 8 details the data used in Figure 10: Requests completed 2024–25 – difference from median total completed days by selected topic.

Table 8: Difference from median total completed days by selected topic
Topic	Difference
Managed Investment Trusts	259.5
International	77
Deductions	74
Withholding Taxes	72.5
Capital Management	28
Superannuation	27
CGT	23
Employee Share Schemes	12
Withholding Tax Exemption	-34
Imputation	-53

Table 9 details the data used in Figure 11: Average RFIs issued per topic 1 July 2023 to 30 June 2025.

Table 9: Average RFIs issued per topic 1 July 2023 to 30 June 2025
Topic	Number of RFIs
Restructure	3.7
Deductions	3.2
ESS	3.1
Withholding Taxes	2.6
CGT	2.5
Capital Management	2.5
All Topics	2.4
Superannuation	2.3
Assessable Income	2.2
International	2.2
WHT Exemption	1.9

Table 10 details the data used in Figure 12: Median RFI response days and median total completion days by selected topic.

Table 10: Median RFI response days and median total completion days by topic
Topic	Median RFI response days	Median total completion days
Withholding Taxes	167.5	465
Managed Investment Trusts	61.5	314
International	68	262
Restructure	73	231.5
Deductions	64	216.5
CGT	59.5	173.5
Employee Share Schemes	65	167
Capital Management	39	144.5
Superannuation	35.5	145

Table 11 details the data used in Figure 13: Outcome of private ruling and class ruling requests 1 July 2020 to 30 June 2025

Table 11: Outcome of class and private ruling requests by year
Outcome	2020–21	2021–22	2022–23	2023–24	2024–25
Favourable	84%	81%	78%	82%	81%
No further action	12%	12%	17%	13%	17%
Refuse to rule	3%	5%	2%	2%	1%
Unfavourable	1%	2%	3%	3%	2%

Table 12 details the data used in Figure 14: Class and private ruling outcomes by taxpayer population 1 July 2020 – 30 June 2025.

Table 12: Outcome of class and private ruling outcomes by taxpayer population for 1 July 2020 to 30 June 2025
Outcome	Top 100	Top 1000	Large Risk	M&E Risk	Outside ADF
Favourable	92%	88%	79%	76%	83%
No further action	7%	8%	18%	18%	14%
Decline to rule	1%	1%	0%	4%	2%
Unfavourable	0%	3%	3%	3%	0%

Table 13 details the data used in Figure 15: Class and private ruling outcomes by most recent income tax assurance rating 1 July 2020 – 30 June 2025.

Table 13: Class and private ruling outcomes by most recent income tax assurance rating
Outcome	High assurance	Medium assurance	Low assurance	Not rated
Favourable outcome	92%	89%	93%	78%
Other outcome	8%	11%	7%	22%

Table 14 details the data used in Figure 16: Class and private ruling requests completed following early engagement by taxpayer population 1 July 2020 – 30 June 2025.

Table 14: Rulings complete following early engagement by population for 1 July 2020 to 30 June 2025
Population	From early engagement	No early engagement
Top 100	55%	45%
Top 1000	44%	56%
Large Risk	46%	54%
M&E Risk	21%	79%
Outside ADF	16%	84%

Table 15 details the data used in Figure 17: Outcome of early engagement requests 1 July 2020 – 30 June 2025.

Table 15: Early engagement requests by outcomes
Outcome	2020–21	2021–22	2022–23	2023–24	2024–25
Progressed to ruling	64%	62%	67%	59%	54%
Progressed to other product	3%	6%	2%	5%	2%
No further action	32%	32%	31%	36%	44%

Table 16 details the data used in Figure 18: Pipeline of early engagement and direct ruling applications through the A&G program.

Table 16: Pipeline of early engagement and direct ruling applications through the A&G program 1 July 2020 to 30 June 2025

Table 16a: Early engagement requests
Outcome of requests	Number of requests
Early engagement requests received	595
Progressed to other product	22
No application lodged	205
Application lodged	368

Table 16b: Early engagement request applications
Outcome of applications	Number of applications
Early engagement requests that progressed to application¹	368
No further action¹	21
Ruling issued¹	319
Favourable ruling	313
Unfavourable ruling	6

Table 16c: Direct ruling applications
Outcome of direct ruling application	Number of applications
Direct ruling applications received	1210
Decline to rule	38
No further action	214
Ruling issued	958

Table 16d: Outcome of direct rulings issued
Outcome of ruling	Number of rulings
Favourable ruling	925
Unfavourable ruling	33

Note 1: These figures do not sum as some early engagement requests have resulted in ruling applications that are still in progress.