Annual Compliance Arrangements with Large Corporate Taxpayers


Positioning of ACAs within the ATO’s Compliance Framework



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ANAO Report 2014-2015 05
Positioning of ACAs within the ATO’s Compliance Framework
(Chapter 3)
26.
ACAs are intended to beat the centre of the ATO’s efforts to develop cooperative compliance relationships with large corporate taxpayers. The ATO initially offered ACAs to the top 50 corporate taxpayers by turnover, and extended this to the top 100 taxpayers when take up numbers were low. In
2011–12, following the introduction of the Risk Differentiation Framework as the ATO’s risk modelling tool, the ATO wrote to 35 of the 133 large corporate taxpayers then rated as key, specifically inviting them to enter into an ACA.
27.
The ATO has also promoted ACAs publicly through various industry groups ATO contacts community and stakeholder forums and regular ATO publications. Despite these efforts, only 24 of the 158 potentially suitable key
19 ATO, Annual Compliance Arrangement Review, draft, September 2014.
20 In addition, ACAs have a steering committee with ultimate responsibility for the ACA and a working group for each tax to provide support to the steering committee.


ANAO Report No 2014–15 Annual Compliance Arrangements with Large Corporate Taxpayers
18 negotiation, operation and sign‐off of the arrangements.
19
While the ATO has taken some steps to improve the administration of ACAs, such as the establishment of the ACA Oversight Committee in June 2012 20
, alack of coordination, intelligence and information exchange across business and service lines was apparent. There has also been considerable slippage in the Committee progressing key elements of its work program, including refining policies, reviewing processes and developing supporting procedures for administering ACAs. These shortcomings belie ACAs being administered as the ATO’s premium cooperative compliance arrangement.
25.
The level of internal and external reporting is proportionate to the scale of ACA activity. However, the ATO has been slow to evaluate the approach to determine if it is achieving the benefits envisaged. The first effectiveness evaluation report is due to be completed late in 2014, although this evaluation project has been ongoing for almost two years. Interim findings from this evaluation, and previous ATO reviews indicate that ACAs have improved relationships with large corporate taxpayers and, in doing so, have potentially supported compliant behaviour. While the interim findings drew on the views of taxpayers and ATO officers about the costs of ACAs, it has not quantified the costs of administering ACAs, the benefits or the impacts on revenue.

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