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What we have learned and the way forward

What we have learned from working with the Top 500 groups in the past year and our focus for the next 12 months.

Published 21 November 2023

The objective of the Top 500 program is to provide the government and the community with assurance that Australia’s wealthiest private groups are paying and will continue to pay, the correct amount of tax. In the medium term, our objective is to provide an affirmative answer and evidence-based assurance for the majority of the Top 500 population.

While our objective may seem simple, the reality is that the Top 500 population is made up of a diverse number of groups that operate over multiple industries, structures and systems. The unique nature of each group requires a specific and tailored approach. In order to place a group into justified trust we invest considerable effort and resources to understanding the group, developing the most appropriate approach to forming an assurance decision and in assessing tax governance. Our approach is also influenced by the taxpayer's willingness to embrace the Top 500 program's model of engagement.

By developing ongoing working relationships with those Top 500 groups who want to comply with their obligations, we build mutual trust, understanding and transparency. In engaging in this way, we develop a better understanding of the operations and structural characteristics of an individual group, which leads to a better experience for our clients and their tax agents. It makes us more efficient in ensuring that the right amount of tax is being paid and serves to avoid disputes and costly compliance action.

Going forward our focus will remain on helping those Top 500 groups who want to demonstrate that they are complying, and will continue to comply, with their tax and super obligations. That includes:

  • focussing the Top 500 population on taking steps to help ensure that they are getting the basics right
  • helping to provide tax certainty over the tax issues arising from succession planning
  • identifying further opportunities to provide differentiated experiences for compliant segments of the Top 500 population via more streamlined approaches to tax assurance and tax governance
  • helping Top 500 groups help themselves with the process of implementing effective tax governance frameworks, processes and procedures to support future compliance.

In those regards we emphasise that the implementation of effective tax governance will support correct reporting and will help ensure Top 500 groups are getting the right advice. It also provides the pathway to justified trust for a large segment of the Top 500 population.

Conversely, there are a relatively small number of Top 500 groups who are not proactively engaged to demonstrate that they are paying the correct amount of tax. We also encounter Top 500 groups who say they wish to demonstrate that they are complying, but who do not engage pro-actively or on an open and transparent basis.

Over the next 12 months we will be increasing our review and audit activities in determining whether Top 500 groups who are not engaged with the Top 500 program are paying the right amount of tax. We will also be focussing on the handful of Top 500 groups who are late in satisfying their BAS payment obligations.

 

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