Annual Compliance Arrangements with Large Corporate Taxpayers



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ANAO Report 2014-2015 05

3.35 As indicated in Chapter 1, part of the ATO’s 2020 vision is that the level of intensity of compliance activity will be tailored according to the taxpayer’s placement on the Client Experience Continuum Model. In this way, the ATO will reward taxpayers openness, transparency and willingness to participate in the tax and superannuation systems with alight touch or no touch experience. A large part of the move to real‐time compliance arrangements are to be automated interactions between the ATO and entities, to present and resolve issues prior to the lodgment of the income tax return. While these aspirations are sound, the ANAO’s recent audit of the Australian Business
93 In response to a recommendation by the Inspector-General of Taxation in the Review into improving
the self assessment system report of August 2012, the ATO has also been examining other countries efforts to improve cooperative compliance with large corporate taxpayers. The June 2014 internal review highlights opportunities for the ATO to learn from approaches adopted in the United States and the Netherlands (as outlined in Chapter 1). This is likely to support the refinement of the ATO’s strategies for the ACA.


ANAO Report No 2014–15 Annual Compliance Arrangements with Large Corporate Taxpayers
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3.32 The low take‐up of ACAs has meant they have not been the centrepiece of cooperative collaboration with large corporate taxpayers as envisaged when introduced. Going forward, the ATO will have to decide whether ACAs are to continue to be positioned in this way, or rather become just apart of the spectrum of compliance approaches. Of prime importance, the ATO will need to clarify the intent of ACAs and how they can be best positioned within the compliance framework for large corporate taxpayers.
3.33 To date, the ATO has not clarified whether to target ACAs to those taxpayers whose compliance behaviours can be improved or to reward those with stronger records of disclosure and compliance. It has also not clarified how to refine ACAs overtime for taxpayers demonstrating a strong record of disclosure and compliance over a number of years. In the latter scenario, ACAs could be more clearly positioned with other compliance approaches to provide a more systematic and coordinated compliance framework for large corporate taxpayers.
3.34 The ATO is currently considering the nature and positioning of ACAs in light of further emphasis on real‐time compliance work as part of the 2020 vision for the ATO. Through this strategy, real‐time pre‐lodgment approaches are to become central for high consequence (higher risk and key taxpayers as categorised in the RDF) taxpayers, as the ATO reduces its focus on traditional post lodgment audits and reviews. ACAs are well placed to beat the forefront of such a strategy.
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