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Intermediaries

Matters currently under consultation for Intermediaries.

Last updated 8 September 2025

[202516] Top 100 GST Program: a changed approach for high assurance GST reporters

Registered

September 2025

Expected completion of consultation

October 2025

Consultation status

We have published a consultation paper seeking feedback on the ATO’s changed approach for high assurance GST reporters. Comments close on 29 September 2025.

Consultation purpose

To seek feedback on the ATO’s changed approach for high assurance GST reporters.

Description

As a result of the assurance obtained over GST in the Top 100 population to date and with the introduction of the Supplementary annual GST return (SAGR), we consider that there is scope to further reduce our engagement and resource investment with overall high assurance GST reporters in GST refresh reviews.

We intend to transition our GST refresh reviews for high assurance reporters who prepare their own GST analytical tool (GAT) prior to lodgment of the SAGR to an Assurance Check-in every 4 years.

Under this approach we will predominantly rely on independent tax control testing results and the alignment between accounting and tax to evidence and maintain assurance, supported by annual profiling.

Consultation will assist us to guide our approach, supported by updated external guidance.

Who we are consulting

  • Top 100 population
  • Intermediaries and advisers
  • Stewardship groups

Consultation lead

Jan Pfitzner, Public Groups
Jan.pfitzner@ato.gov.au

[202515] Public country-by-country report lodgment instruction

Registered

August 2025

Expected completion of consultation

October 2025

Consultation status

Consultation is planned to commence in September.

Consultation purpose

To seek feedback on the draft Public country-by-country (CBC) report lodgment instruction to ensure it is clear, fit-for-purpose, and supports consistent, meaningful and comparable public reporting.

Description

The Public CBC reporting regime is a transparency measure first announced in the 2022–23 Budget and enacted in December 2024. It requires large multinational enterprises (MNEs) with annual global income exceeding $1 billion and Australian-sourced income of at least $10 million to publicly disclose selected financial and tax information.

The regime differs from the confidential CBC reporting regime, as it requires CBC reporting entities to make selected data available to the public. This includes disclosure on revenues, profits, taxes paid, and the group’s approach to tax.

Australia’s implementation is considered world-leading, mandating broader and more detailed disclosures than comparable regimes such as the European Union’s Public CBC framework.

Given the scope and novelty of the regime, we anticipate that in-scope CBC reporting entities will require clear guidance on:

  • information that must be included in their annual Public CBC report
  • the level of detail expected in both quantitative and qualitative disclosures
  • how to interpret and apply the legislation and accompanying guidance in practice.

We are undertaking consultation to:

  • seek stakeholder views on draft guidance materials
  • clarify stakeholder expectations around disclosure formats and content
  • identify practical challenges and areas where further clarification may be needed.

Feedback will ensure guidance supports consistent, meaningful, and comparable public reporting.

Who we are consulting

  • Community
  • Professional associations
  • Industry representatives
  • Large Business Stewardship Group
  • Significant global entities
  • Multinational enterprises

Consultation lead

Patricia Wang, Public Groups
PublicCBC@ato.gov.au

[202511] Review of the tax treatment of digital assets and transactions in Australia

Registered

June 2025

Expected completion of consultation

June 2026

Consultation status

Targeted and phased consultation is planned to commence in September.

Consultation purpose

To seek comment and feedback on proposed public advice and guidance, such as draft taxation determinations, on crypto issues raised in the Board of Taxation’s report, to provide more detailed guidance to taxpayers.

Description

The Board of Taxation's report on its review of the tax treatment of digital assets and transactions in AustraliaExternal Link recommended the ATO establish regular consultation on crypto issues raised in its report. The Crypto Industry Working Group will consult with crypto industry representatives and academic experts, taxation law and accounting representative bodies and relevant government agencies on proposed public advice and guidance and other related tax products to ensure they meet the needs of taxpayers and stakeholders.

Who we are consulting

  • Taxation law and accounting representative bodies
  • Crypto industry representatives
  • Crypto academic experts
  • Relevant government agencies

Consultation lead

Timothy Beale, Office of the Chief Tax Counsel
Timothy.Beale@ato.gov.au



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