ACA strategy and alignment with other compliance approaches 3.28 As discussed previously, the ATO is moving towards greater cooperative collaboration with large corporate taxpayers, with ACAs intended to promote real‐time engagement. However, the ATO also has other 89 Senior Executive Relationship Managers conduct a program of regular visits with the taxpayer to discuss significant events that may have tax implications, revenue performance, risk, technical and service issues and the progress and conduct of any compliance activity. 90 ATO, Large business bulletin, December 2013, p. 6, available at < https://www.ato.gov.au/uploadedFiles/Content/LB_I/downloads/PGI_qc38038_nat71246_js29773.pdf > accessed 15 July 2014]. The bulletin is a quarterly online publication aimed at large business and contains up-to-date information on income tax, GST, excise and superannuation matters with links to recent rulings, speeches and media releases. Positioning of ACAs within the ATO’s Compliance Framework ANAO Report No 2014–15 Annual Compliance Arrangements with Large Corporate Taxpayers 65 compliance approaches with purposes similar to ACAs—in particular pre‐lodgment compliance reviews for income tax and key taxpayer reviews for GST. The interaction and overlap of these approaches, together with the relatively extensive ACA processes, has led industry representatives and others to question the strategy and positioning of ACAs within the overall compliance framework for large corporate taxpayers. 3.29 ACAs are voluntary arrangements, offered to taxpayers with strong governance arrangements and a willingness to disclose contentious tax positions and risks in real time. It would therefore be reasonable to expect the administrative demands on ACA holders (and the ATO) to be lower than alternative compliance approaches. However, this is often not the case. Undercurrent arrangements, ACA holders are required to provide written assurance confirming they have good governance and risk management processes, develop a compliance plan, disclose material risks and tax positions, participate in an annual review, and develop and implement mitigation strategies in respect of any risks that cannot be resolved at the time of the annual review. Table 3.4 outlines the other compliance approaches for large corporate taxpayers.