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. Summary ANAO Report No 2014–15 Annual Compliance Arrangements with Large Corporate Taxpayers 19 taxpayers (15 percent) had entered into an ACA by July The low level of participation has been raised in a number of recent reviews, and the ATO is consequently considering options for improving take‐up. Of prime importance is the need to clarify the purpose of ACAs 22 and to develop a strategy for positioning these arrangements within the compliance framework for large corporate taxpayers. 28. There is scope for the ATO to better differentiate the operation and administrative requirements of ACAs from other compliance activities, and better align the benefits and costs across the range of compliance activities for large corporate taxpayers. In this way, the requirements for administering and participating in an ACA would be proportional to the level of risk associated with the specific taxpayer and support the effective use of resources by the ATO and taxpayers. 29. Developing a comprehensive compliance strategy for large corporate taxpayers that clearly distinguishes ACAs from other compliance activities would enable the ATO to more actively market ACAs.