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4. GST compliance

How the ATO addressed GST compliance engagement in 2023–24 including registration, lodgment and payment.

Published 1 January 2025

Registration

GST registration is the front door to the GST system. In assisting taxpayers to correctly register for GST, we enable them to both enter and exit the GST system as required.

GST registrants increased slightly this year with 3.4 million businesses registered at 30 June 2024.

For new GST registrants, we delivered tailored education to assist them to get it right from the start and develop positive behavioural practices.

We continue to maintain the integrity of the GST client register with our ATO-initiated activities to identify and remove (cancel) GST clients who:

  • incorrectly registered
  • incorrectly left the system (no longer require their GST registration but failed to cancel it).

Table 4.2 shows little change in the proportion of entities that declare business income (more than $75,000) in their income tax returns to compulsory registrants. This indicator assesses whether we have the right number of registrants in the system and is reported one year in arrears due to reliance on corresponding income tax data.

Table 4.1: GST registrations

Type

2019–20

2020–21

2021–22

2022–23

2023–24

Total GST registrants

2,910,000

3,080,000

3,250,000

3,320,000

3,420,000

- Non-reporting registrants

n/a

n/a

86,000

87,000

91,000

New registrations

371,000

409,000

496,000

445,000

436,000

Cancelled registrations

263,000

253,000

294,000

363,000

331,000

Notes: Non-reporting registrants occur where one member of a GST group manages the affairs of the group and is responsible for accounting for the GST transactions of the whole group, but each group member must be individually registered for GST to form part of the GST group. This group is included in the total number of GST registrations.
Table 4.2: Compulsory GST registrations compared to potential GST registrations (%)

Type of measure

2019–20

2020–21

2021–22

2022–23

2023–24

Compulsory GST registrations compared to potential GST registrations

96.6

97.2

96.9

97.2

97.3

Note: GST Performance Agreement Schedule A 5e.
Table 4.3: Total registered client base by client experience (million)

Category

2019–20

2020–21

2021–22

2022–23

2023–24

Small business

n/a

2.40

2.51

2.55

2.61

Privately owned and wealthy groups

n/a

0.40

0.47

0.48

0.51

Public and multinational businesses

n/a

0.08

0.08

0.08

0.09

Not-for-profit

n/a

0.07

0.07

0.08

0.08

Other

n/a

0.12

0.13

0.12

0.13

Total registered client base

2.91

3.08

3.25

3.32

3.42

Note: GST Performance Agreement Schedule A 8c.
Table 4.4: Australian Business Registry Services (ABRS) registrations (%)

Type of measure

2019–20

2020–21

2021–22

2022–23

2023–24

Australian resident ABRS registrations finalised in 20 business days

99

99

99

98

99

Notes: GST Performance Agreement Schedule A 9g. The taxpayer charter standard of 93% target applies. The percentile has remained steady and continued to exceed the target.

Cross-border services and goods

We continue to administer the cross-border GST. Of the $1.6 billion paid by the 2,600 non-resident GST registrants, $42 million was directly attributable to our compliance activities.

Our education and compliance activities resulted in 386 new non-resident GST registrants in 2023–24, an increase of 37% from the previous year.

A one-month campaign in late 2023 to increase awareness of Australian GST obligations for non-resident businesses in United States of America and United Kingdom resulted in:

  • close to 3 million impressions (the number of times seen)
  • a significant increase in traffic to the relevant GST content on our website with over 10,000 page views during the campaign, compared with 1,012 in the previous month
  • 56% increase in new non-resident GST registrants in the 6 months after the campaign compared to the same period the year before.

Table 4.5 observes a 22% increase in GST revenue from businesses making supplies of low value imported goods. This is largely attributed to one entity remitting $115 million.

Internationally, we chair an Organisation for Economic Co-operation and Development (OECD) focus group designed to enhance international consistency of GST policy design and support tax administrations in improving GST compliance in digital trade.

Australia’s active involvement in this international GST dialogue ensures the effective exchange of insights, experiences, and intelligence on risks, trends, and emerging issues. This strengthens our capacity to respond to the challenges of administering GST in a global digital economy.

Improved use of card-payment data sourced from the Australian banking sector has identified non-resident businesses with unmet GST obligations related to the supplies of goods and services they make to Australian consumers.

This has provided new opportunities to differentiate our risk management approach, implement targeted education and compliance strategies and ensure a level playing field between non-resident and domestic businesses.

Table 4.5: Value of cross-border services and goods ($m)

Category

2019–20

2020–21

2021–22

2022–23

2023–24

Imported services GST

550

700

780

805

875

Imported low value goods GST

420

500

565

610

745

Total

975

1,200

1,340

1,410

1,620

Notes: GST Performance Agreement Schedule A 4a–b. All figures have been rounded to the nearest $5 million.

Lodgment and payment

Our focus remains to foster on-time lodgment and payment behaviours and prevent future debt by making it easier to pay. We pursue outstanding payments and demonstrate the consequences of avoiding payment obligations by:

  • advising those who can pay, they must pay on time
  • firmer action for those choosing not to engage or pay
  • supporting those struggling but have the capacity to pay to get back on track
  • supporting those without capacity to pay to exit the system.

Lodgment

Approximately 7.2 million on-time BAS lodgments were received in 2023–24. This was around 303,000 more than 2022–23. The BAS on-time lodgment performance increased slightly this year by 0.4 percentage points.

As shown in Tables 4.6 and 4.7 below, there is a noticeable change in the 2023–24 monthly and quarterly results when compared to previous years. From this year, we are using the GST period date, which more accurately reflects if the taxpayer’s GST lodgment period is monthly or quarterly. Previously, we used the activity statement period dates.

As part of our ongoing commitment to ensure registration of entities are correct, we identified taxpayers demonstrating no signs of active operations for GST purposes and removed them from our BAS lodgment population. We notified them of this decision and provided guidance on how to re-establish their GST registration if required. Our actions have reduced unnecessary correspondence and interactions.

Whilst our initial focus this year has been on small businesses, we will be expanding these integrity improvements to other entities.

External communications will also increase to educate taxpayers on the need to cancel GST and ABN registrations where they are no longer required. This will ensure we can better target active entities who are failing to meet their lodgment obligations.

Table 4.6: Total BAS lodged (%)

Type of lodgment

2019–20

2020–21

2021–22

2022–23

2023–24

Lodged (monthly)

90.8

89.9

88.9

87.3

81.9

Lodged (quarterly)

82.3

81.9

80.9

82.0

83.7

Total BAS lodged

84.6

84.1

83.1

83.4

83.4

Note: GST Performance Agreement Schedule A 5f.
Table 4.7: Total BAS lodged on time (%)

Type of lodgment

2019–20

2020–21

2021–22

2022–23

2023–24

Lodged on time (monthly)

81.8

78.5

76.1

76.3

69.0

Lodged on time (quarterly)

71.0

67.3

67.9

69.3

72.2

Total lodged on time

74.0

70.3

70.1

71.2

71.6

Notes: GST Performance Agreement Schedule A 5f. BAS lodged within 7 days of the due date is regarded as lodged on time.
Table 4.8: Electronic activity statements finalised within 12 business days (%)

Type of measure

2019–20

2020–21

2021–22

2022–23

2023–24

Proportion finalised within 12 business days

99.7

99.2

98.7

99.7

99.7

Notes: GST Performance Agreement Schedule A 9c. This service commitment has a 94% target.
Table 4.9: Percentage of BAS lodged electronically (%)

BAS lodgment frequency

2019–20

2020–21

2021–22

2022–23

2023–24

Monthly remitters

87.4

92.2

93.3

94.5

94.7

Quarterly remitters

88.2

88.4

92.1

89.8

94.3

Annual remitters

91.3

95.0

95.5

95.4

96.8

Overall

88.2

88.9

92.3

90.4

94.5

Note: GST Performance Agreement Schedule A 9d.
Table 4.10: GST returns filed by intermediaries or tax agents (%)

Type of measure

2019–20

2020–21

2021–22

2022–23

2023–24

BAS filed by intermediaries or tax agents

55.4

56.6

56.6

58.9

59.6

Note: GST Performance Agreement Schedule A 9h.

Payment

In the 12 months to 30 June 2024:

  • total ATO collectable debt increased 5.2%
  • GST collectable debt increased 2.6%
  • the ratio of GST collectable debt to GST collections (cash) reduced from 15.8% to 15.6%.

To support a healthy economic system and protect the community we are responding with a firmer approach earlier to recover outstanding GST debts.

The slowing of the growth in GST collectable debt indicates our firmer actions may be starting to slow and stabilise the increase of collectable debt.

Current year results reflect a revised calculation including real time payments. Previously, we used the date we processed a payment.

Table 4.11: Outstanding GST debts ($m)

Type of GST debt

2019–20

2020–21

2021–22

2022–23

2023–24

Total debt outstanding

10,185

10,660

12,302

15,930

17,162

- Collectable debt

7,869

8,766

10,366

12,883

13,217

- Insolvent debt

n/a

1,628

1,819

2,664

3,474

- Disputed debt

n/a

265

117

383

471

Notes: GST Performance Agreement Schedule A 3a. Collectable debt is debt for which there is no impediment to collection – it is not subject to objection, appeal, or to some form of insolvency administration.

Figure 4.1 Ageing of GST collectable debt by value

Figure 4.1

Note: Age of debt is determined by the later of the processed date or the effective date of the transactions.
Table 4.12: Ratio of collectable debt to GST revenue (%)

Type of collection

2019–20

2020–21

2021–22

2022–23

2023–24

Tax liability method (TLM) accrual

11.8

12.1

13.6

15.0

14.9

Cash

13.1

12.0

14.1

15.8

15.6

Notes: GST Performance Agreement Schedule A 3b. The debt collection rate is calculated using the GST collectable debt amount as a percentage of 12 month rolling GST (TLM accrual or cash) collections.

By identifying and removing non-pursuable debt (irrecoverable at law or uneconomical to pursue) from collection activities, we can focus our attention on the right cases. The return to normal collection activities following COVID-19 has resulted in increases in the identification of debts that are irrecoverable at law or uneconomical to pursue this year. This is shown in Table 4.13 which compares non-pursuable debt to both total GST debt and GST revenue.

Table 4.14 shows whilst the number of GST payments paid on time has decreased slightly, the value of those payments paid on time is at its highest level in 5 years at 88.5%.

Additionally, due in part to our tailored engagement approaches including leveraging through our tax practitioner community and media, we receive 95.2% of payments within 90 days of the due date.

Table 4.13: Non-pursuable GST debts (%)

Type of measure

2019–20

2020–21

2021–22

2022–23

2023–24

GST debt non-pursuable to total GST debt

4.3

5.1

5.4

4.6

11.5

Ratio of GST debt non-pursuable to GST revenue

0.7

0.7

0.9

0.9

2.3

Note: GST Performance Agreement Schedule A 3c.
Table 4.14: GST on-time payment rate (%)

Type of measure

2019–20

2020–21

2021–22

2022–23

2023–24

GST payments made on time

76.3

73.0

70.4

71.3

71.1

Value of GST paid on time

86.5

85.9

85.8

87.7

88.5

Note: GST Performance Agreement Schedule A 3d.
Table 4.15: Ageing of GST collectable debt – value ($m)

Category

2019–20

2020–21

2021–22

2022–23

2023–24

<1 month

1,006

835

905

1,069

1,019

1–2 months

1,705

1,270

1,352

1,717

1,777

2–3 months

470

248

341

275

292

3–12 months

2,701

2,745

3,712

3,475

3,684

>1 year

1,987

3,668

4,056

6,346

6,444

Total GST debt value

7,869

8,766

10,366

12,883

13,217

Notes: GST Performance Agreement Schedule A 3e. Age of debt is determined by the latter of the processed date or the effective date of the transaction(s).

Compliance engagement

In 2023–24, the ATO raised $3.0 billion in liabilities through compliance activities. The results have returned to normal levels following the impacts of Operation Protego in 2021–22 and 2022–23.

We continue to strengthen and enhance the management and oversight of the GST system, with an emphasis on:

  • identifying and remediating system vulnerabilities
  • reducing non-compliance
  • mitigating emerging threats to the system.

Through 2023–24 our Contemporising GST Risk Model project designed improved analytical risk models to target risks and behaviours that impact the integrity of the GST system. These models increased our capability to effectively manage GST compliance risks.

Emphasis has been placed on assessing and treating fraud, including actions to better understand and enhance our management of GST fraud.

The ATO Counter Fraud Strategy announced in Budget 2024 has bolstered our ability to fight back against the growth in identity crime-enabled fraud and scaled fraud attacks across our digital services. These attacks are agile, prolonged, and persistent. The risk is amplified by global threats, organised crime, and increasing numbers of data breaches in the community.

Ongoing investment to place downward pressure on GST risk will allow us to continue our emphasis on preventative and detected measures. This allows us to respond to increasingly agile and sophisticated actors, safeguarding the system against misuse, and ensure taxpayers’ compliance.

Emerging threats

Shadow economy behaviour continues to evolve through the proliferation of digital technology such as electronic sales suppression tools (ESSTs).

Due to an increasing digital economy and specifically, more payment service providers, the risk posed by ESSTs is estimated to have tripled in the last 3 years. Manufacturers and suppliers of ESSTs are well-funded, well-resourced, and technologically advanced.

ESSTs understate sales for GST and income tax purposes. This rapidly evolving technology with integrated functionality across business systems allows users to access point of sales systems remotely to delete, re-sequence or manipulate records. We are working domestically and internationally to disrupt the manufacture, supply and use of these ESSTs.

We are seeing an increasing prevalence of sophisticated structuring arrangements between inter-related parties in the privately owned and wealthy groups market. The arrangements are primarily undertaken to obscure transactions and disguise artificial or fraudulent arrangements resulting in high value GST refunds. These arrangements often involve high value purported transactions or purchases, such as purchases of real property.

We believe there are groups or networks of industry participants within established related party groups who are involved in commercial arrangements which seek to exploit the GST rules in relation to interparty transactions including through:

  • false invoicing between related entities (for example issuing invoices where no goods or services are provided)
  • deliberately misaligning GST accounting methodologies across the group (for example one entity operating on a non-cash (accrual) basis whilst another utilises a cash basis in order to contrive a GST refund due to the mismatched timing of the methodologies)
  • duplicating GST credit claims in related entities for a single high value transaction
  • claiming GST credits for purported purchases, development, and construction (by related entities) which never occurred.

We will effectively deal with those who engage in GST Fraud, false invoicing or other illegal financial arrangements, including through working with partner agencies where appropriate.

Compliance liabilities

In Tables 4.17 and 4.18, the cash collection rate from client engagement activities is based on collections within the year that relate to the liabilities raised in that year only. On the other hand, total cash collections (excluding penalties and interest) estimated within the year can also include collections that relate to compliance liabilities raised in previous years.

Table 4.16: Compliance liabilities ($m)

Type of measure

2019–20

2020–21

2021–22

2022–23

2023–24

GST liabilities raised

2,645

2,339

5,407

4,829

2,958

Table 4.17: GST compliance liabilities raised by client experience

Client experience

GST compliance liabilities $m

Within year compliance cash collection $m

Cash collection rate %

Total compliance cash collections $m

Small business

1,503.6

894.5

59.5

1,253.4

Privately owned and wealthy groups

1,078.1

731.0

67.8

893.4

Public and multinational businesses

363.8

302.6

83.2

317.1

Not-for-profit

-9.3

-23.0

247.7

-21.4

Other

21.7

18.5

85.1

22.9

Total

2,957.9

1,923.6

65.0

2,465.4

Notes: GST performance Agreement Schedule A 5b. Cash collections on those liabilities in the financial year, cash collection rate within the year, and total cash compliance collections.
Table 4.18: GST compliance liabilities raised by industry

Category

GST compliance liabilities $m

Within year compliance cash collections $m

Cash collection rate %

Total compliance cash collections $m

Construction

959.3

638.5

66.6

824.6

Professional, scientific and technical services

465.1

337.9

72.7

395.7

Administrative and support services

224.1

159.6

71.2

176.4

Rental, hiring and real estate services

220.6

147.8

67.0

188.3

Transport, postal and warehousing

212.1

149.8

70.6

193.6

All other

876.7

489.9

55.9

686.9

Total

2,957.9

1,923.6

65.0

2,465.4

Notes: GST Performance Agreement Schedule A 5b. Cash collections on those liabilities in the financial year, cash collection rate within the year, and total cash compliance collections.
Table 4.19: Return on investment from compliance activities (ratio)

Type of activity

2019–20

2020–21

2021–22

2022–23

2023–24

Business as usual

7.0:1

7.9:1

10.4:1

10.6:1

8.3:1

GST Compliance Program

15.5:1

11.3:1

30.1:1

23.5:1

12.9:1

Note: GST Performance Agreement Schedule A 5g.
Table 4.20: Strike rate by client experience (%)

Client experience

2019–20

2020–21

2021–22

2022–23

2023–24

Small business

n/a

87

95

83

73

Privately owned and wealthy groups

n/a

66

62

56

53

Public and multinational businesses*

n/a

75

53

56

55

Not-for-profit*

n/a

81

35

47

54

Other

n/a

85

92

92

88

Overall

80

86

94

84

73

Notes: GST Performance Agreement Schedule A 5c. The strike rate (percentage of cases leading to re-assessment) is an OECD measure that can indicate the effectiveness of case selection in detecting non-compliance.
*The strike rate for categories with low case number can fluctuate dramatically from one reporting period to the next.

GST refunds random audit program

We have completed our first comprehensive evaluation of the GST risk models. The data will provide valuable insights into the real-world performance of our machine-learning models.

Our evaluation focussed on assessing the GST high risk refund models performance, specifically examining the accuracy and effectiveness of the Incorrect reporting model and the Identity crime model.

In the ever-evolving landscape of GST refund integrity, distinguishing between genuine identity (ID) crime and deliberate incorrect reporting is crucial.

By analysing audit results, we evaluate the accuracy and reliability of these models to ensure they reflect the actual risk scenarios we encounter.

By refining our models and incorporating additional risk factors, we enhance our ability to protect taxpayers and maintain the integrity of the GST system.

4.21: Refund integrity active compliance GST liabilities raised by client experience ($m)

Client experience

2019–20

2020–21

2021–22

2022–23

2023–24

Small business

n/a

374

2,688

2,054

517

Individuals

n/a

18

388

459

34

Privately owned and wealthy groups

n/a

66

86

130

251

Public and multinational businesses

n/a

19

23

10

41

Not-for-profit

n/a

4

10

12

2

Other

n/a

2

2

4

1

Total

306

484

3,198

2,668

846

Note: GST Performance Agreement Schedule A 5d.
Table 4.22: Refund integrity strike rate by client experience (%)

Client experience

2019–20

2020–21

2021–22

2022–23

2023–24

Small business

n/a

95

98

88

78

Individuals

n/a

98

97

95

94

Privately owned and wealthy groups

n/a

74

70

65

51

Public and multinational businesses*

n/a

85

50

66

57

Not-for-profit*

n/a

92

36

56

54

Other*

n/a

92

40

57

60

Total

85

94

97

89

78

Notes: GST Performance Agreement Schedule A 5d. This measure applies to cases where a refund has been held by the ATO. When considered over time, this measure will indicate if improvements have been made to the ATO’s risk-based audit selection strategy.
* The strike rate for client experiences with low case numbers can fluctuate dramatically from one reporting period to the next.

Prosecutions and investigations

Criminal investigations and prosecutions as part of a ‘consequence strategy’ remain our firmest actions to protect the GST system against fraud and related crimes.

We are working with our state and territory partners through the ATO-led Serious Financial Crime Taskforce. Operation Protego is an example of effectively partnering with law enforcement agencies and the Commonwealth Department of Public Prosecutions (CDPP).

In 2023–24:

  • 18 of the 26 criminal investigations we completed proceeded to a prosecution referral
  • successful prosecutions in 11 cases referred to CDPP resulted in
    • 9 custodial sentences
    • over $24,000 in fines
    • over $656,000 in reparation orders
  • under Operation Protego, an additional 43 people were convicted of fraud with sentences including jail terms. Four Operation Protego investigations remain in progress.

We build community trust and confidence in ATO by leveraging successful prosecutions of evident risks through targeted media and communication activities.

Notable CDPP-led prosecutions completed under the Criminal Code Act 1995

A taxpayer was charged for dishonestly causing risk or loss to the Commonwealth with a loss to the ATO of over $900,000. It was found that approximately 50 BAS lodged by the person for 2 businesses contained false information. Due to a guilty plea, they received a reduced 4 years and 9 months sentence with a 30-month non-parole period.

Under Operation Protego, a taxpayer was charged for obtaining financial advantage by deception and for attempting to obtain a financial benefit by deception. He was sentenced to 7 years and 6 months imprisonment with a non-parole period of 5 years. Orders were also made to restrain real property.

Notable ATO-led prosecutions completed under the Taxation Administration Act 1953 (TAA)

Magistrates continue to impose large penalties for individuals who fail to meet their GST obligations. Convictions and fines include:

  • $40,000 for failing to lodge 28 GST and 8 income tax returns
  • $28,000 for failing to lodge 13 GST and 5 personal income tax returns, and 6 super fund income tax returns as a trustee
  • $15,000 for failing to lodge 1 GST and 3 income tax returns.

 

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