Question 7
At Question 7 of the Supplementary annual GST return 2025, you must indicate whether you've had material business changes or material systems changes that impact your GST control framework since your most recent GST assurance review.
You must answer either 'Yes' or 'No'.
If you answer 'Yes', you must describe the material business or material systems changes.
If you answer 'No', continue to Question 8.
Question 8
At Question 8, you must assess whether you meet the criteria needed to maintain or increase your GST governance stage rating for the period the return covers, when compared to the previous stage rating given to you by us in your most recent GST assurance review.
You must answer either:
- Yes – maintained
- Yes – increased, or
- No.
Question 9
At Question 9, you must explain your reasoning to support your response to Question 8, including how you have taken into account any:
- governance uplifts, for example where you have
- documented your end-to-end BAS process (Managerial-level control (MLC) 6), or
- developed an internal controls testing program (Board-level control (BLC) 4)
- material changes to your business or systems, for example a new enterprise resource planning (ERP) system (MLC 4) or mergers and acquisitions (M&A) activity (BLC 1).
Self-assessing your tax control framework
Our GST governance, data testing and transaction testing guide sets out the requirements for each GST governance stage rating in section 3.2.
Your answer to Question 8 is to enable us to understand how you self-assess your tax control framework for GST with reference to the criteria contained in our guide.
For example, if you received a Stage 2 GST governance rating in your most recent GST assurance review you would answer:
- Yes – maintained – if you consider you meet the criteria to maintain a Stage 2 rating
- Yes – increased – if you consider you meet the criteria to increase to Stage 3
- No – if you have not met the criteria to maintain a Stage 2 rating.
While Question 8 asks for your self-assessment, please note that an increase in your governance rating can only be issued by the ATO in the context of an assurance review, where we look for objective evidence to assess your framework using the staged rating system outlined in the GST governance, data testing and transaction testing guide.
Resources to help you answer these questions
The best resource to assist you with answering these questions will be:
- your GST governance stage rating (as well as, for Top 100 taxpayers, the rating for each individual control), which is recorded in the final report you received at the completion of your most recent GST assurance review
- any further communications you have had with us in relation to particular issues or recommendations
- our GST governance, data testing and transaction testing guide which sets out the requirements for each GST governance stage rating in section 3.2.
When considering your response, you should take into account:
- your prior governance ratings received in your GST assurance reviews
- whether you have implemented our recommendations or actioned any commitments made to us
- if you have made any material changes to your business or systems that impact your GST control framework. If so, you should consider whether you have maintained or improved your GST governance rating with regard to the criteria set out in our GST governance, data testing and transaction testing guide.
Example 1: 'Yes – maintained' at Question 8
Orbit Kings is a Top 1,000 taxpayer who receives an overall medium assurance rating and a Stage 2 GST governance rating. As part of its previous combined assurance review, Orbit Kings provided a Board endorsed commitment to start periodic internal controls testing. The commitment specifies a timeframe for the testing to commence for GST in 2023–24.
Orbit Kings has started its periodic internal controls testing in accordance with its commitment and has otherwise met the criteria to maintain its Stage 2 rating. However as only some of the controls have been tested at this stage, it doesn't meet the criteria to increase to a Stage 3 rating.
As there have been no material changes to its business or systems, Orbit Kings answers 'No' to Question 7. In providing its response to Question 8 of the Supplementary annual GST return, Orbit Kings answers 'Yes – maintained'. Orbit Kings provides an explanation at Question 9 that it considers it meets the criteria to maintain its Stage 2 GST governance rating because it has started its periodic internal controls testing in accordance with its commitment and has otherwise met the criteria to maintain the rating.
As our assurance report recommended that Orbit Kings evidence the operational effectiveness of its tax control framework in practice with reference to the requirements in the GST governance, data testing and transaction testing guide. Orbit Kings also includes the details of the internal controls testing that has been conducted and its plan for completing testing in its answer to Questions 5 and 6 in Section B.
End of exampleExample 2: 'No' at Question 8
Frankie Wholesale is a Top 1,000 taxpayer who received an overall medium assurance rating and a Stage 2 GST governance rating in its combined assurance review report issued in March 2023.
In November 2023, Frankie Wholesale acquired Lulu Food Manufacturing who makes taxable and GST-free food supplies. Lulu Food Manufacturing doesn't currently have any documented GST procedures, processes or controls in place for the supplies that it makes.
As there have been material changes to its business and systems, Frankie Wholesale answers 'Yes' to Question 7, and it explains that it has acquired a new food manufacturing entity that doesn't have documented GST procedures, processes or control framework in place for the supplies that it makes.
Frankie Wholesale reviews the GST governance, data testing and transaction testing guide and at Question 8, it answers 'No' as it considers it doesn't meet the criteria to maintain its Stage 2 GST governance rating at that point in time. At Question 9, it explains that it hasn't yet implemented updated tax governance controls or documented its GST processes, policies or procedures that relate to the supplies and acquisitions made by Lulu Wholesale.
End of exampleExample 3: 'Yes – maintained' at Question 8
Wilson Sports is a Top 1,000 taxpayer. It received a GST streamlined assurance review report in 2023, with an overall high GST assurance rating and a Stage 2 GST governance rating.
In 2024, Wilson Sports implemented a new Information Technology (IT) system that resulted in material changes to the business systems it uses to collate and report GST impacted transactions.
Given these changes, Wilson Sports reviewed the design effectiveness of its controls, including Managerial-level control 4 (MLC 4) (Controls in place for data for GST purposes) to consider if it had maintained a Stage 2 GST governance rating. Wilson Sports considered whether, given the changes in its IT systems, it still had effectively designed GST data controls, including documentation which evidences GST controls built into business systems as well as standard rules for assigning tax codes and process for setting up, adding and deleting of customer and vendor master files and tax codes.
It considers that it has objective evidence to maintain its GST governance rating in line with the GST governance, data testing and transaction testing guide.
Wilson Sports answers 'Yes' to Question 7 and provides comments describing the material change in its systems. It answers 'Yes – maintained' to Question 8 and at Question 9 explains the process it has undertaken to determine that it has maintained its GST governance rating.
Wilson Sports retains evidence of the steps it took to support its responses to the questions in Section C.
End of exampleContinue to Section D: Question 10.
Return to Instructions to complete the Supplementary annual GST return 2025.