Annual Compliance Arrangements with Large Corporate Taxpayers



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ANAO Report 2014-2015 05
Annual ACA review
4.51 The purpose of the annual review is to review the taxpayer’s tax risks and transactions for the year so that the year can be signed off or mitigation strategies can be developed for any high risk issues. ATO guidance provides


ANAO Report No 2014–15 Annual Compliance Arrangements with Large Corporate Taxpayers
86 parties and usually includes members from the ATO’s compliance team and senior officers from the taxpayer’s tax area.
4.48 In terms of managing multi‐tax ACAs that cross BSLs, four taxpayers advised that they would prefer to see a more unified approach from the ATO. One ATO officer responsible for 11 GST ACAs (of which five include cross BSL
ACAs) also advised that there is scope to work more closely across BSLs where there are multiple taxes included in the ACA that are administered in separate
BSLs. This was also part of the rationale for establishing the ACA Oversight Committee in June 2012.
4.49 The ATO’s 2012 Review of Annual Compliance Arrangements also found that there was scope to improve the real‐time engagement approach where ACAs were being managed across BSLs. The review stated that real‐time engagement should occur as one ATO and not replicated for each arrangement. The review noted that although client teams are monitoring the media and Australian Securities Exchange announcements to varying degrees, and irrespective of other ACAs, the LB&I now PG&I] team should liaise with their Indirect Tax business line colleagues to be briefed on any movements or irregularities in the monthly Business Activity Statements lodged. Any irregularities could instigate a proactive real time discussion with the client and may elicit disclosures that may not have otherwise been initiated by the taxpayer at that time. It would further demonstrate to the taxpayer that we the ATO] have areal time engagement with them.
4.50 In this light, there would be merit in the ATO continuing to enhance the role of the ACA Oversight Committee in coordinating ACAs across BSLs. The
ATO could also identify better ways of working more closely across BSLs at the individual team level. This might include formalising meetings between ATO compliance officers that are not in the same BSL or enhanced information sharing arrangements regarding ACA holders. Currently meetings between
ATO compliance officers indifferent BSLs only occur on an ad hoc basis and information sharing across BSLs occurs predominantly at the ACA Oversight Committee or the steering committees rather than at the compliance team level.

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