Overview of the program
The Top 1,000 combined (income tax and GST) assurance program is part of the Tax avoidance taskforce. It replaces the Top 1,000 tax performance program that ended in 2020 and the Top 1,000 GST assurance program that ends this year.
Specialist tax performance teams engage with each taxpayer using tailored assurance approaches. We seek to increase our assurance that large public and multinational groups are reporting the right amount of income tax and GST or identify areas of tax risk for further action.
The program provides large businesses with an opportunity to gain greater certainty about their tax outcomes and the effectiveness of their tax governance frameworks. It also provides an objective mechanism for large businesses to understand how their tax profile compares to others in the market and their peers.
The program builds on previous assurance engagements. This enables us to 'top up' our understanding. We will not seek the same level of information as that required in your previous assurance review unless there are significant changes.
The reviews provide an opportunity to improve assurance ratings obtained under previous reviews as we review improvements and steps taken to address our concerns.
By following our guidance and recommendations and providing information requested in a timely manner, taxpayers are less likely to experience protracted reviews or follow on compliance activity.
Who the program covers
The Top 1,000 combined assurance program covers large public and multinational companies, with turnover above $250 million. This includes taxpayers we've engaged with through income tax and GST assurance reviews.
This program doesn't include taxpayers in the Top 100 Program.
Our combined assurance review
We apply our justified trust methodology in our combined assurance reviews. Each review covers income tax and GST. Where we have already engaged through an income tax or GST assurance review, we will tailor the review based on the outcomes of those previous engagements.
The review seeks to increase our level of assurance that you're reporting the right amount of income tax and GST or identify areas of income tax or GST risk for further action.
If we have engaged with you through an earlier income tax or GST assurance review, we leverage our understanding of your business and seek to ‘top up’ our assurance and focus on what has changed since that review. We also check you've addressed any recommendations from your previous review. You will be able to improve your assurance ratings by following these recommendations.
We focus on the last complete financial year for GST. If we haven't engaged with you through an income tax assurance review, the income tax component of the review will be more comprehensive and cover a 4-year period.
Early notification of your review
We will notify you before we start a combined assurance review and provide you with our request for information giving you time to complete responses.
You will have a short period of time to consider whether to make a voluntary disclosure in respect of any errors or omissions.
Our request for information is a list of questions that asks you to provide some of the information in a standard template format. Most taxpayers will have a request to complete the GST analytical tool. If you were identified as a predominantly input taxed supply business then we will undertake data testing in place of the GST analytical tool.
On receipt of the information, we may follow up with additional questions where required.
We understand that circumstances and needs may vary between large businesses. While we have clear commitments, we continue to be empathetic to your needs, and we will work with you to adapt the timing of the review to your circumstances.
How we tailor your review
We tailor the combined assurance review to your circumstances having regard to:
- your assurance outcomes from any previous income tax or GST assurance engagement
- the steps you have taken to address recommendations in any previous income tax or GST assurance engagement
- how you have applied our published guidance – we will ask whether you have considered and applied our public guidance relevant to your circumstances including, reviewing your tax governance using our
- Tax risk management and governance practical review guide to prepare for a combined assurance review
- GST Governance, Data Testing and Transaction Testing Guide
- how you respond to our request for information for your combined assurance review – you should provide us with timely, accurate and complete responses to our questions.
Importance of timely and complete responses
We consider the provision of timely and complete responses to our request for information may indicate the presence of stronger tax governance frameworks and a willingness to engage with us to obtain better review outcomes. Where this occurs, we will seek to tailor your engagement with us through:
- shorter reviews
- shorter combined tax assurance reports
- less intensive engagements.
If your responses don't meet our expectations, it is likely that you will be asked detailed questions and experience a longer more intensive review process.
How to prepare and improve review outcomes
We expect you to take steps to ensure you understand our justified trust methodology and assurance approaches to prepare for your review.
The below practical guidance can help you prepare for a review and improve your review outcome.
Income Tax:
- Tax risk management and governance - a practical guide to prepare for a combined assurance review (income tax)
- How to obtain higher assurance outcomes (income tax)
- Top 1,000 what attracts our attention (income tax)
- Typical questions in a Top 1,000 combined assurance review.
GST:
- GST Governance, Data Testing and Transaction Testing Guide
- GST analytical tool
- GST what information we need from you.
More information can be found by visiting:
- The Top 1,000 Findings Report (income tax and GST) - helps you understand the key areas where we are unable to obtain assurance
- Make a voluntary disclosure
- APRA-regulated funds tax controls for third party data.
We continue to update our guidance to help you obtain better outcomes from the review.
What to expect following a review
Following a combined assurance review we will share our findings with you, including:
- discussing the areas where we have assurance you have reported the right amount of income tax and GST
- any identified income tax and/or GST risks
We will provide separate assurance ratings for income tax and GST. We may recommend specific actions to obtain greater assurance or address identified income tax or GST risks and may follow up on these recommendations. We may also refer you for further compliance activity.
Findings report
Our Findings Report Top 1,000 income tax and GST assurance programs June 2021 includes our key findings from the income tax streamlined assurance reviews covering 926 taxpayers as well as the Top 1,000 GST assurance program and Top 1,000 Combined Assurance Review program.
The report will help you understand how we apply the justified trust methodology to obtain greater assurance that large public and multinational taxpayers are paying the right amount of income tax or identify areas of tax risk for further action.
Assures the income tax and goods and services tax (GST) affairs of Australia's Top 1,000 population.