The questions we have listed are indicative of the questions all taxpayers will be asked in a combined assurance review. This may assist you to prepare early for an assurance review.
We might ask additional questions about specific industry risks or significant issues which we identify may be relevant to your business – for example, financial supplies, GST on low value imported goods, digital supplies.
We have grouped these questions under the following headings:
General questions
Group structure
Provide details of all members of your GST Group and details of any changes to the membership of the GST group during the review period.
Provide a brief description of how you identify and track transactions between the GST group members (both supplies and acquisitions) and non-grouped entities (including non-resident GST registered entities) in your corporate group to ensure they are treated correctly for GST purposes. This will include covering where you report these in your BAS.
Provide details of related entities (Australian resident and/or non-resident) which are GST registered but are not part of your GST group(s).
Nature of supplies
A description of the nature of the supplies you made and, if you are a member of a GST group, the nature of the supplies each entity in your GST group made. For example, headings for your responses could include:
- taxable supplies
- GST-free supplies
- input taxed financial supplies
- supplies that are out of scope of the GST regime
- mixed supplies
- nature of acquisitions.
A description of the nature of the acquisitions you made and if you are a member of a GST group, the nature of the acquisitions each entity in the GST group made. The following headings may assist your response preparations:
- creditable acquisitions
- financial acquisitions
- acquisitions that relate to making input taxed supplies (other than financial supplies)
- acquisitions that are of a private or domestic nature.
Business Activity Statements and Workpapers
In respect to your monthly BAS lodged during the review period, provide:
- a copy of all workpapers and reports used in the preparation of the GST disclosures on the BAS and evidence of the monthly approval process (this will usually be for 3 months only)
- for the last month of the review period, an electronic copy of all workpapers and reports extracted from your systems to calculate your GST obligations or manual spreadsheets including the GST general ledger transactional data used to support the amount reported at 1A and 1B.
Reliance on ATO advice
We will ask if have advice from the ATO on the application of GST laws to a transaction or arrangement including a private binding ruling in the review period. We will request evidence that you followed the advice including if the facts and circumstances had changed from what the advice was provided for.
Systems for processing GST information
Provide the following information for the past 4 years for all information systems which capture GST information, including point of sale, enterprise resource planning, optical character recognition and expense management systems:
- name of system and the versions
- when each system was implemented/upgraded or ceased to be used
- who owns and maintains the GST master data (such as customer master files, product master files etc.) and the name of system where controlled
- frequency of archival process for transactional data such as sales and accounts payable
- how the files are protected orsegregated
- if applicable, locations of any overseas accounting orprocessing systems, detailing how staff qualifications, systems and procedures meet Australian GST legislative requirements.
Document retention
Detail where and how the following information is retained and processes that are in place to ensure document retention requirements under the taxation laws are met:
- tax invoices, recipient created tax invoices, adjustment notes, expenses claims
- BAS
- objective evidence for tax governance.
Supplies
Cancellation Fees
Have you charged any fees to a customer when an intended supply does not eventuate?
If yes, provide a brief description, including the value and GST treatment.
Consignment Goods
Did you make any supplies by way of consignment (sale or return)?
If yes, provide a brief description of the supplies made, the value and the controls in place to ensure GST is correctly accounted for.
Deposits
Did you receive deposits or part payments?
If yes, we will ask for a description of the deposit or payments including details of how you treated it and sample invoices.
Employee contributions for Fringe Benefits
Did you receive any post tax contributions from employees for fringe benefits?
If yes, we will ask for a details including how they were treated for GST.
Exports
Did you export goods or services? If yes, we will ask for details of the goods or services including how you determine the treatment for GST and evidence you met the criteria for the GST treatment.
Intangibles
Have you acquired any services from an offshore entity (that is, located outside the indirect tax zone) or made any cross-border digital supplies and/or acquisitions?
If yes, provide a brief description including the value and how these transactions were treated for GST purposes.
Inbound intangible consumer supplies and low value imported goods
Are you part of a GST group that has non-Australian resident members?
If yes, did any non-resident group member supply from offshore to Australian consumers any inbound intangible supplies (such as digital products & services) and/or any low value imported goods (<$1,000)? If yes, we will ask for details of the entity, the supplies and how they were treated for GST.
Lay-by sale
Did you make supplies under lay-by arrangements?
If yes, provide a brief description of the scheme, the value and GST treatment including when GST is accounted for and what occurs if a lay-by is cancelled.
Mixed Supplies
Did you make mixed supplies during the review period?
If yes, we will ask for details of the supplies, how you characterise them and how your accounting system is configured to calculate the GST.
Property
Did you make any supplies or acquisitions of real property during the period of review? For example:
- commercial or residential land
- unimproved land – potential residential land
- farmland
- student accommodation
- social housing
- community housing
- affordable housing
- build to rent
- commercial residential premises
- retirement villages.
If yes, we will ask for details of the transactions and how they have been treated for GST.
Significant business transactions / events (supplies and/or acquisitions)
Did any entity in the GST group make any significant or new transactions including, but not limited to:
- sale or acquisition of land
- acquisition or disposal of any business entities (include any share and/or asset transactions)
- mergers or restructures (equity structure)
- international dealings
- new products, services, business lines
- other financial supplies – for example, financing (including related party)?
If yes, provide a brief description of those transactions including the value of those transactions and how they were treated for GST purposes.
Vouchers / reward cards
Did you supply vouchers/gift or reward cards during the review period?
If yes, we will ask for details of the vouchers, volume and value of the cards and what controls are in pace to ensure GST is reported correctly.
Warranty services
Did you provide a warranty on any goods sold during the review period?
If yes, provide a brief description of the warranty services, including the value and the GST treatment. For example, free-of-charge warranty repairs or replacements, extended warranty services, payments to disgruntled customers (ex gratia payments), discounted prices on replacement goods.
Acquisitions
Allowances
During the review period did you pay allowances to staff and/or contractors versus reimbursement for expenses incurred on your behalf, such as a daily per diem when they are away from home on business or cents per kilometre for business use of their private vehicle?
If yes, we will ask for details of the allowances and any input tax credits claimed.
Financial Acquisitions Threshold
During the review period did you undertake any transactions which gave rise to the issue, sale or purchase of shares in a company or units in a trust, or any other financial supplies (e.g. hedging, currency/forex, swap contracts, debt raising etc)?
If yes,
- provide a copy of any advice obtained and workpapers which show reviews undertaken in respect of the GST treatment of supplies and acquisitions made as part of the transaction
- describe how you monitored the costs that related to making the financial supplies, including any element of general overheads – provide any relevant documented policies and procedures that were in place to support your response
- describe how you monitored whether you exceeded the financial acquisitions threshold, and what was the result – provide a copy of your FAT testing workpapers for the review period (if available)
- did you recover any input taxed credits or reduced input tax credits on the costs that related to making financial supplies – if so, what were the type and amount of costs and for reduced input taxed credits, under what item of GST subsection 70-5.02(1) of the GST Act were these claimed under?
- did you incur any costs from overseas in relation to the transaction and if so, did you consider how these should be included in the financial acquisitions threshold test and if the reverse charge under Division 84 of the GST Act should be applied? Provide a copy of relevant workpapers to support your response (if available).
Finance lease and hire purchase
During the review period did you enter into any finance lease and hire purchase arrangements?
If yes, provide the value of these transactions and a description of how you treated those transactions for GST purposes.
Imports and deferred GST
During the review period did you import any goods?
If yes, provide:
- a brief description of the goods you imported and the value of the imports
- details of the entity or entities listed as the importer as per the customs documentation.
Is the entity listed as importer approved under the deferred GST scheme?
If yes, detail any checks undertaken of the amounts pre-populated at Label 7A of the BAS.
Input Tax Credit (ITC) Estimator
Did you use any form of an input tax credit estimator to bring forward the claiming of input tax credits on unprocessed tax invoices at month end or quarter end during the review period?
If yes, detail the methodology used to determine your input tax credit entitlement for the review period, such as on actual invoices received but not processed, monthly average and the controls in place to ensure that input tax credits are not claimed twice after the invoices are processed in the next month.
Material or unusual transactions
Did you undertake any unusual, material, or one-off acquisitions such as capital acquisitions undertaken during the review period?
If yes, provide a brief description of these transactions.
Non-deductible expenses - entertainment
During the review period did you claim any input tax credits on entertainment expense items that are not otherwise deductible under income tax law?
If yes, we will ask for details on what method you used to determine your non-deductible entertainment and an outline of the volume and value of these expenses and your GST controls for ensuring you only claim input tax credits for the eligible portion.
Recipient Created Tax Invoices (RCTIs)
Did you issue or receive any RCTI as part of your business operation during the review period?
If yes:
- confirm there is a written agreement in place between the parties
- provide a description of the arrangements including the value and volume of transactions and how they are treated for GST purposes
- provide a sample of RCTIs
- describe how you monitor the GST registration status of any suppliers to whom you issue recipient created tax invoices.
Second-hand goods
Have you claimed any input tax credits throughout the review period on second-hand goods acquired from unregistered suppliers?
If yes, provide a brief description of the items acquired and the amount of input tax credits claimed.
Staff expenses
Did you use a corporate credit card or reimburse staff for out of pocket expenses?
If yes:
- confirm if these expenses include items which are not subject to GST such as international travel and accommodation overseas
- confirm whether staff process their own expense claims and the evidence required for each item
- confirm whether local accommodation was booked through online platforms
- outline the volume and value of these expenses and your GST controls for ensuring you only claim input tax credits for expenses subject to GST.
Adjustment events
This includes discounts, rebates, returns and incentive payments.
Did you provide any of the following or receive the following payments from your suppliers:
- settlement discounts
- volume rebates
- advertising rebates
- promotional rebates
- sales returns and allowances
- purchase returns and allowances
- reward cards.
If yes, we will ask for information for each type including:
- a description of the arrangements including the value and volume of transactions and how they are treated for GST purposes, with a particular focus on whether you treat them as a discount to the invoiced price, adjustment event or as a separate supply of services and the label they are reported in the BAS
- details of the controls you have in place to ensure that any adjustments to an earlier acquisition price or selling price are processed correctly for GST purposes
- a sample of the tax invoices and adjustment notes.
Special rules andspecific issues
Agency arrangements
During the period of review did you undertake any transactions where you act either as agent or principal under an agency arrangement or a principal and intermediary under Division 57 or Division 153B of the GST Act?
If yes:
- confirm there is a written agreement in place between the parties
- provide a description of the arrangements including the value and volume of transactions and how they are treated for GST purposes
- include a sample of tax invoices and adjustment notes.
Associates – related party transactions
During the review period were there any related party transactions with associates outside of the GST group?
If yes:
- provide a brief description, including the value and GST treatment of the transactions
- confirm whether any transactions were provided free-of-charge or at a reduced value to an entity which is not registered for GST or would not be entitled to claim an input tax credit had the supply been subject to GST – for example, it makes input taxed financial supplies.
Government grants
Were you in receipt of any government grants or financial assistance payments during the review period?
If yes, provide a brief description including the value and how this is treated for GST purposes, including details of any paperwork that is issued such as tax invoices, RCTIs etc."
Insurance claims
Have you received any monies relating to an insurance claim during the review period?
If yes, for each premium paid to which a claim applies, specify the amount of the claim and what entitlement to input tax credits was communicated to the insurer and when.
Joint ventures
Have any economic group members participated in, been operator for or entered into joint venture arrangements or transactions during the review period?
If yes:
- provide a brief description (including if those joint ventures are registered as GST joint ventures) and the GST treatment of transactions
- if you or a member of your GST group is a joint venture operator:
- provide a copy of the joint venture agreement and any supporting documents; and
- advise if the joint venture operator is lodging BAS and if so, provide details of the GST registration.
Non-monetary consideration
During the review period were you a party to any transactions where non-monetary consideration was used?
If yes, provide a brief description of the arrangements including the value and volume and outline the GST controls in place to ensure they are correctly treated for GST purposes.
Settlement payments/damages
During the period of review were you a party to any transactions concerning a settlement or damages payment?
If yes, provide a brief description including the value and how this was treated for GST purposes.