Ratings tables − Public and multinational business advice and guidance program

Table 1 details the data used in Chart 2: Private ruling, class ruling, guidance and early engagement requests received and completed by product type 1 July 2020 to 30 June 2024.

Table 1: Total requests received by year

Type of request	2020–21	2021–22	2022–23	2023–24
Private rulings	314	314	197	257
Class rulings	58	106	68	66
Early engagement	153	144	106	73
Guidance	55	72	76	41

Table 2 details the data used in Chart 3: Top 10 topics - Private rulings, class rulings, guidance and early engagement received 2023–24.

Table 2: Top 10 topics for 2023–24

Topic	Total requests received
WHT Exemption	87
CGT	73
Employee Share Schemes	63
Capital Management	62
Managed Investment Trusts	24
Discretions	15
Superannuation	15
International	13
Deductions	13
Withholding Taxes	11

Table 3 details the data used in Chart 4: Top 5 topics - Private rulings, class rulings, guidance and early engagement received 1 July 2020 – 30 June 2024.

Table 3: Top 5 topics received between 1 July 2020 and 30 June 2024, by year

Topic	2020–21	2021–22	2022–23	2023–24
WHT Exemption	121	85	61	87
Capital Management	97	114	76	62
CGT	76	105	73	73
ESS	54	73	53	63
International	30	29	40	13

Table 4 details the data used in Chart 5: Private rulings, class rulings, guidance and early engagement received by taxpayer population 1 July 2020 – 30 June 2024.

Table 4: Request types received by population type, by year

Population type	2020–21	2021–22	2022–23	2023–24
Top 100	75	91	56	36
Top 1,000	166	184	128	130
Medium	106	128	82	89
Emerging	138	162	133	119
Outside ADF	95	71	48	63

Table 5 details the data used in Chart 6: Private rulings, class rulings, early engagements and guidance requests received by most recent income tax assurance review rating 1 July 2020 – 30 June 2024.

Table 5: Private rulings, class rulings, early engagements and guidance requests received by most recent IT assurance rating

Assurance rating	2020–21	2021–22	2022–23	2023–24
High assurance	80	96	56	40
Medium assurance	61	61	46	48
Low assurance	16	19	11	4

Table 6 details the data used in Chart 8: Private rulings, class rulings, guidance and early engagement received by advisor type 1 July 2020 – 30 June 2024.

Table 6: Products received by advisor type

Advisor type	2020–21	2021–22	2022–23	2023–24
Big 4 firm	298	343	215	226
Other firm	191	195	174	164
Taxpayer lodged	91	98	58	47

Table 7 details the data used in Chart 10: Median total days to complete request by product 1 July 2020 – 30 June 2024.

Table 7: Median completion days

Row labels	2020–21	2021–22	2022–23	2023–24
Private rulings	141	141	160	148
Class rulings	198	163.5	197	186
Guidance	110	99	87.5	87

Table 8 details the data used in Chart 11: Private rulings, class ruling and guidance requests completed 2023–24 - difference from median total completed days by selected topic.

Table 8: Difference from median total completed days by selected topic

Topic	Difference
Withholding taxes	375
Managed investment trusts	123
Deductions	54.5
Employee Share Schemes	35.5
International	33.5
CGT	13.5
Superannuation	-6
Capital Management	-11
Withholding tax exemption	-32
Discretions	-83.5

Table 9 details the data used in Chart 12: Private ruling, class ruling, guidance and early engagement requests completed 2023-24 – difference from median RFI response days by selected topic.

Table 9: Difference from median RFI response days by selected topic

Topic	Difference
Withholding taxes	132
Deductions	74.5
Employee Share Schemes	13
Withholding tax exemption	-2.5
Managed investment trusts	-4
Capital Management	-8.5
Superannuation	-11
CGT	-18
International	-19
Discretions	-21.5

Table 10 details the data used in Chart 13: Outcome of class and private ruling requests 1 July 2020 – 30 June 2024.

Table 10: Outcome of class and private ruling requests by year

Outcome	2020–21	2021–22	2022–23	2023–24
Favourable	84%	81%	78%	82%
No further action	12%	12%	17%	13%
Refuse to rule	3%	5%	2%	2%
Unfavourable	1%	2%	3%	3%

Table 11 details the data used in Chart 14: Class and private ruling outcomes by taxpayer population 1 July 2020 – 30 June 2024.

Table 11: Outcome of class and private ruling outcomes by taxpayer population for 1 July 2020 to 30 June 2024

Outcome	Top 100	Top 1,000	Medium	Emerging	Outside ADF
Favourable	92%	89%	70%	77%	80%
No further action	7%	9%	24%	13%	15%
Refuse to rule	1%	1%	1%	6%	4%
Unfavourable	0%	2%	5%	3%	1%

Table 12 details the data used in Chart 15: Class and private ruling requests completed following early engagement by taxpayer population - 1 July 2020 – 30 June 2024.

Table 12: Rulings complete following early engagement by population for 1 July 2020 to 30 June 2024

Population	From early engagement	No early engagement
Top 100	54%	46%
Top 1,000	44%	56%
Medium	26%	74%
Emerging	16%	84%
Outside ADF	17%	83%

Table 13 details the data used in Chart 16: Class and private ruling outcomes by most recent income tax assurance rating - 1 July 2020 – 30 June 2024.

Table 13: Class and private ruling outcomes by most recent income tax assurance rating

Outcome	High assurance	Medium assurance	Low assurance
Favourable outcome	91%	90%	96%
No further action	8%	9%	4%
Refuse to rule	1%	0%	0%
Unfavourable	1%	2%	0%
Other outcome	9%	10%	4%

Table 14 details the data used in Chart 17: Outcome of early engagement requests 1 July 2020 – 30 June 2024.

Table 14: Early engagement requests by outcomes

Outcome	2020–21	2021–22	2022–23	2023–24
Progressed to ruling	64%	63%	69%	61%
Progressed to other product	3%	6%	2%	5%
No further action	32%	31%	29%	34%