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Section D: Reconciliation between audited financial statements and Business Activity Statements

What to include and resources to help you answer questions 7 to 10.

Published 2 October 2024

Question 7

At question 7, you must confirm if you have completed the GST Analytical Tool (GAT) reconciliation or a similar reconciliation, to understand the variance between your audited financial statements and GST reported on your Business Activity Statements for the period the return covers.

If you answer yes, continue to question 8.

If you answer no, continue to question 10.

Question 8

If you answered yes at question 7, you must provide your effective net GST rate for the year under this reconciliation.

Continue to question 9.

Question 9

If you answered yes at question 7, you must also answer whether you can explain any unreconciled amounts and provide a brief explanation of your response.

Continue to Section E, Question 11.

Question 10

If you answered no at question 7, you must provide a response as to why you didn't complete the GAT or a similar reconciliation for the period the return covers (for example, if your business is predominantly input-taxed).

Continue to Section E, question 11.

Resources to help you answer this question

The best resources to help you answer this question will be:

In responding, note that:

  • under Managerial Level Control (MLC) 7: Procedures to explain significant differences, our existing expectation is that large corporate taxpayers will implement documented procedures for an annual reconciliation process, as per the ATO's GST governance, data testing and transaction testing guide.
  • we do not expect a full reconciliation of the activity statements to the accounts, and there is no predetermined set variance for the percentage differences and/or dollar values in assessing GAT outcomes that we expect. We do not expect a transaction-level analysis to be undertaken. Taxpayers should apply their judgment and provide a reasonable response that considers their circumstances.
  • you should keep objective evidence to support your response, such as the workings for your derived effective net GST rate, including for all adjustments made to arrive at that number. Our expectation is that if you disclose that unreconciled amounts can be explained, you will have evidence to support explanations for why the variances are reasonable (which may include qualitative explanations).

Example 1: 'Yes' at question 7

Siu Metals is a Top 1,000 taxpayer. The GAT was conducted in Siu Metals' first Combined Assurance Review.

Siu Metals uses its documented procedures to undertake the GAT for the 2024–25 financial year to understand variances between its financial statements and GST reporting. There have been no substantial changes to Siu Metals' business, and the same assumptions can be used in undertaking the GAT as during the Combined Assurance Review.

Siu Metals:

  • answers yes at question 7, as it has conducted the GAT to understand the variance between its financial statements and activity statements for the period the return covers
  • includes at question 8 that the effective net GST rate for the year under the calculations was 9.8%
  • answers yes at question 9. It explains that the unreconciled amounts can be explained by foreign exchange differences as a result of different functional currencies being used, which represents the majority of the 0.2% variance.

Siu Metals retains evidence of the methodology (including the assumptions) and calculation, and evidence to support the conclusion that unreconciled amounts can be explained, to support its responses in section D.

End of example

Example 2: 'No' at question 7

Spurge Bank is a Top 100 taxpayer. In its GST Assurance Report, the GAT was not undertaken because it is a business with predominantly input-taxed supplies.

In providing its response to question 7, Spurge Bank disclosed that it hasn't conducted a reconciliation between its audited financial statements and activity statements for the period the return covers. At question 10, it provides brief comments that this is because it is a predominantly input-taxed business.

Spurge Bank does not need to complete questions 8 or 9.

End of example

Continue to Section E, Question 11.

Return to Instructions to complete the Supplementary annual GST return 2025.

QC103046