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Action Differentiation Framework

How we use the Action Differentiation Framework (ADF) to engage with Public and Multinational Businesses (PMBs).

Last updated 1 August 2024

How we engage with you

We tailor and differentiate the way we engage with you. We do this based on:

  • size and complexity of your business
  • transparency of your engagement with us
  • choices and behaviours evidenced in your tax affairs
  • the level of risk you exhibit.

The ADF allows us to:

  • use resources efficiently - allocating them to focus areas and where attention is required
  • focus on the principles of obtaining justified trust.

Engagement frequency

Under the ADF, you are grouped into populations based on your total business income (TBI).

Population and TBI

ADF

Definition

Level of engagement

Large corporate
groups

(Greater than $250m TBI)

Top 100

Our largest corporate groups by TBI, plus those of strategic significance

Large corporate
groups

(Greater than $250m TBI)

Top 1,000

Our largest corporate entities outside the Top 100

Large corporate
groups

(Greater than $250m TBI)

Large
risk strategy

Large market entities which are not covered by the Top 100 or Top 1,000 programs

  • Depending on risk factors, periodic one-to-one engagement or compliance engagement through medium PMB engagement program
  • Other compliance engagement

Medium and emerging
groups

(Less than $250m TBI)

Medium and emerging
risk strategy

All other PMB groups

Engagement experience

The ADF guides us on how we tailor our engagement with you across a range of services and approaches.

Partnering

  • We partner with you to maintain good compliance.
  • If you're willing to engage with us and are transparent in your compliance, we'll partner with you to deliver our services promptly to help you meet your tax obligations.
  • We'll generally adopt a less intensive approach in our interactions with you, reducing your compliance costs.

Encouraging  

  • We encourage you to address our concerns.
  • If you take positions relating to complex arrangements giving rise to significant tax risks, we'll request that you address our concerns.
  • We encourage you to improve your level of assurance over your affairs by using our tailored services and approaches according to your circumstances.
  • We'll work with you to improve future transparency and compliance.

Influencing  

  • We take firm action to encourage compliance.
  • If you are not transparent and consistently take high risk positions, we'll adopt –an intensive approach to ensure we address risks.
  • We tailor our services and approaches to your characteristics and behaviours.
  • We adopt firm approaches and exercise formal powers for information gathering until you improve your transparency and compliance.

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