How we develop our insights
We have a dedicated workforce monitoring, reviewing, assuring and engaging with the largest public and multinational groups in Australia. We continue to publish the results from our key programs to provide transparency about the health of the tax system and the effectiveness of our engagement approaches.
These results and insights are available in the following reports:
- Findings report RTP – Public and multinational businesses
- Findings report – Top 100 income tax and GST assurance programs
- Findings report – Top 1,000 income tax and GST assurance programs
- Findings report – Public and multinational business tax certainty programs
- Findings report – Public and multinational business disputes and outcomes
Strong assurance outcomes through engagement
This year, we continue to observe high levels of assurance across large public and multinational businesses.
For the Top 100 population:
- 82% achieved either high or medium assurance for income tax.
- 98% achieved either high or medium assurance for GST.
For the Top 1,000 population:
- 89% achieved either high or medium assurance for income tax.
- 95% achieved either high or medium assurance for GST.
These assurance ratings continue to give us confidence that most large businesses are paying the right amount of tax and reporting the right GST outcomes.
Of the $61.5 billion income tax paid by Top 100 economic groups in 2024, $52.9 billion was paid by taxpayers with high or medium assurance. Nearly all the $11.9 billion GST reported, and paid, by reviewed Top 100 GST reporters is attributable to taxpayers with high or medium assurance. More than 95% of Top 100 taxpayers now have current-year justified trust reviews underway. Of those, 80% have no past-year justified trust reviews outstanding.
In the Top 100 population, we continue to see improvements in governance outcomes for income tax. More than half of taxpayers achieved the highest governance rating (Stage 3) for income tax, while GST governance outcomes remained strong, with 61% of Top 100 GST reporters achieving a Stage 2 or Stage 3 rating.
Positive trends continue across the Top 1,000 population, with assurance outcomes steadily improving over recent years. Of the $38.4 billion income tax paid by taxpayers in the Top 1,000 population in 2023–24, $32.5 billion was paid by taxpayers given a high or medium assurance rating in their latest review.
We continue to tailor our engagement according to a taxpayer's assurance level, risk profile and tax performance. We focus resources on taxpayers and issues that require greater scrutiny, while reducing the intensity of our engagement for taxpayers with strong governance and higher levels of assurance. Our findings continue to show timely disclosures and proactively addressing issues raised through assurance reviews contributes to improved and sustained assurance outcomes over time.
Our tax certainty programs also continue to support willing participation and early engagement. Demand for tax certainty continued to grow in 2025–26, with requests increasing by 10% as taxpayers seek greater certainty before implementing significant transactions or lodging returns. In 2025–26, 94% of rulings issued had favourable outcomes, and early engagement remains an effective way to identify and resolve issues before disputes arise.
How data and reporting help us to understand tax performance
Data and information provided through reporting obligations are critical to our understanding of tax performance across the large business market.
We use information from tax returns (including the Reportable Tax Position and International dealings schedules), business activity statements, country-by-country reporting, and Supplementary annual GST returns to:
- identify emerging risks and behavioural trends across the market
- understand the drivers of tax performance and non-performance
- detect and monitor systemic risks
- tailor our engagement approaches
- target assurance and compliance activities where they are most needed.
This information helps us develop a more holistic view of taxpayer behaviour, tax performance and identify emerging risks. We combine these insights with data analytics, risk models and assurance activities to build a comprehensive picture of large business tax performance. This allows us to focus on prevention before correction and target assurance, advice and compliance activities where they are most effective.
This intelligence supports our assurance, tax certainty and compliance programs and helps us maintain confidence in the health of the corporate tax system.
The public and multinational business three - tier model (3TM)
The public and multinational business three-tier model (3TM) is our framework for understanding tax performance across the large market. The model leverages the OECD's four pillars of compliance and helps us understand the behaviours, events and focus areas that drive tax performance and non-performance.
Our justified trust assurance programs provide an important foundation for our levels of confidence about tax compliance across the various behaviours identified by the 3TM. This year our findings reports also show our findings through a 3TM lens.
Increased transparency
The number of Reportable tax position (RTP) schedule disclosures has increased by over a third. The number of schedules lodged has steadily increased by 14% over the 4 years from 2021–22 to 2024–25. This reflects the progressive expansion of lodgment requirements and growth in the reporting population. The Top 1,000 population remains the largest lodging and disclosure population, consistent with the applicable lodgment thresholds.
Consistent with our focus on engagement, assurance and providing guidance on risk, we found there were increased low-risk arrangements and a decrease, or no change, in the proportion of high-risk disclosures.
Improved compliance and dispute outcomes
While large business remains one of the most compliant segments of the tax system, we continue to maintain a strong compliance presence to address significant risks where they arise.
During 2025–26:
- we raised $2.05 billion in total income tax liabilities
- we raised around $305 million in GST liabilities
- a further $2.2 billion was paid voluntarily from prior compliance activities and preventative engagement.
Global profit shifting, international related party dealings and cross-border investment structures remain key focus areas across our compliance and dispute programs.
Where appropriate, we continue to resolve disputes through settlement. During 2025–26 we settled 30 disputes involving public and multinational businesses, securing around $1.31 billion in tax revenue while securing future behavioural commitments and greater certainty.
Turning insights into action
Our observations continue to align with broader measures of large business tax performance, including Corporate tax transparency and Large corporate groups income tax gap.
While we're confident most public and multinational businesses continue to meet their obligations, ongoing engagement remains important.
During 2025–26, we:
- continued our focus on real-time justified trust engagement with Top 100 taxpayers
- embedded the supplementary annual GST return (SAGR) as an important mechanism for maintaining GST assurance
- continued to enhance our advice and guidance, and advance pricing arrangement programs to provide greater certainty
- used insights from assurance, tax certainty, RTP and compliance programs to refine our risk identification and engagement approaches.
Our findings continue to show sustained engagement, strong governance, greater transparency and early disclosure encourage improved taxpayer behaviours, higher assurance outcomes and increased confidence in the large business tax system.