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. Positioning of ACAs within the ATO’s Compliance Framework
ANAO Report No 2014–15 Annual Compliance Arrangements with Large Corporate Taxpayers
69 Register, administered partly by the ATO, found considerable scope to improve whole‐of‐government coordination arrangements for dealing with business.
94
3.36 Notwithstanding the intent of, and progress in implementing, the
ATO’s 2020 vision, there is scope for the ATO to better differentiate ACAs from other compliance activities, and better align the benefits and costs across the range of compliance activities for large corporate taxpayers.
Conclusion
3.37 While the ATO has positioned ACAs as the centrepiece of its cooperative compliance approaches, participation in the arrangement has been low. Only 24 of 158 potentially suitable key taxpayers, as categorised under the
RDF, had entered into an ACA by July 2014. Further, of the 24 current ACAs, six would not be categorised as key taxpayers under the RDF if they were not already in an ACA. The ATO has not effectively leveraged off the RDF or developed a suitable marketing strategy to attract taxpayers to enter into
ACAs. To improve participation, the ATO has conducted a number of reviews of the arrangement, and is considering the purpose of ACAs and where these arrangements fit within the compliance framework for large corporate taxpayers.
3.38 The main considerations for the ATO in this regard include whether to limit ACAs for use as a tool for changing taxpayers behaviour and improving their governance arrangements to address tax risks or have more graduated administrative processes that are less onerous for taxpayers with a strong compliance record, which would make ACAs more attractive to taxpayers. At the same time, the ATO needs to better differentiate alternative compliance approaches, such as pre‐lodgment compliance reviews and key taxpayer reviews, to align benefits and costs across the range of compliance approaches for large corporate taxpayers. Refining the overall compliance strategy for large corporate taxpayers, inline with its 2020 vision, would better position the
ATO to actively market ACAs, to attract the appropriate number and type of taxpayers.
94 ANAO, Audit Report No 2013–14 Administration of the Australian Business Register, pp. 17–18.


ANAO Report No 2014–15 Annual Compliance Arrangements with Large Corporate Taxpayers
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