Applying justified trust to the top 100 population
Justified trust is a concept from the Organisation for Economic Cooperation and Development (OECD).
We originally introduced the justified trust concept starting with the top 100 population in 2016.
We complete justified trust reviews as part of the yearly pre-lodgment compliance review (PCR). The Engaging early with you publication has information on:
- what to expect in a PCR
- PCR timelines
- our expectations around pre-lodgment disclosures.
In these reviews, we apply consistent rating categories to our overall level of assurance. We apply a high assurance rating where we have confidence that you paid the right amount of income tax for the period reviewed.
Due to the size and complexity of taxpayers in the top 100 population, we expect it may take some taxpayers several years to reach high assurance.
We are working with each of the top 100 as part of the PCR process to gain and maintain a high level of assurance. We will tailor future engagements to focus on new, unassured areas and changes.
The Top 100 program − Tailored approach to obtaining, maintaining and refreshing assurance outlines the stages of the Justified Trust cycle for income tax.
High level of assurance
When you, as a top 100 taxpayer, attain an overall high level of assurance under our justified trust program, it means we have confidence that you've complied with Australian income tax laws.
In recognition of the level of trust we have in the reported tax outcomes of these taxpayers, we will tailor our future engagement approach to focus on maintaining our high level of confidence. This is known as the monitoring and maintenance approach. This approach will apply to taxpayers for the 3 income years following an overall high assurance outcome.
To reaffirm our confidence that you continue to pay the right amount of income tax, we will refresh our understanding and evidence base every fourth income year. We do this by running a refreshed justified trust review (refresh review).
Top 100 Findings report
Our Findings report – Top 100 income tax and GST assurance programs covers our key findings from tax assurance reviews completed to 30 June 2024.
These findings will help you understand how we apply the justified trust methodology to either:
- have greater assurance that top 100 taxpayers are paying the right amount of income tax or GST
- identify areas of tax risk for further action.
For more information about the Top 100 program, email Top100@ato.gov.au.