Annual Compliance Arrangements with Large Corporate Taxpayers



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ANAO Report 2014-2015 05
Reviews of ACAs
13.
In the last two years, ACAs have been the subject of a review by the
Inspector‐General of Taxation
11
and four ATO internal reviews. The most recent internal review, at draft report stage in September 2014, considered the findings and recommendations of the previous reviews, which had highlighted scope to improve technical and strategic aspects of ACAs, particularly those
11 Inspector General of Taxation, Review into Improving the Self-Assessment System, August 2012.
12 The internal reviews included the Review of Annual Compliance Arrangements (based on the views of
ATO officers managing income tax ACAs), November 2012; PG&I ACA Community Involvement Workshop, February 2014; Annual Compliance Arrangements Strategy Review (GST), April 2014; and
Annual Compliance Arrangements (ACA) Review, draft, September 2014.


ANAO Report No 2014–15 Annual Compliance Arrangements with Large Corporate Taxpayers
14
11.
The ATO has adopted the following three‐phase process for entering into and administering ACAs: entry into the ACA—where the taxpayer’s governance arrangements are confirmed and a terms of arrangement document developed that sets out how the ACA will work administration throughout the year—where the taxpayer continuously discloses material tax risks and the ATO reviews these disclosures and closure at the end of the financial year—where the ATO and the taxpayer jointly review the taxpayer’s tax return. The ATO provides sign‐off for low risk tax issues and develops mitigation strategies to address higher risk issues. The renewal of the ACA is also covered during this stage.
12.
If the taxpayer voluntarily enters into an ACA, the ATO has agreed not to apply alternative compliance approaches, such as

pre‐lodgment compliance reviews—used to identify and assess large corporate taxpayers income tax risks in the pre and post‐lodgment periods

reportable tax position schedules—many large corporate taxpayers are required to disclose their more contestable and material income tax positions and key taxpayer reviews—piloted in 2013–14 for the goods and services tax (GST) and excise, and implementation will be considered during the development of the 2014–15 Compliance Plan.

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