External review of ACAs 1.23 In August 2012 the Inspector‐General of Taxation published the Review into Improving the Self‐Assessment System which referenced ACAs. 40 The Inspector‐General’s concerns and observations included ACAs are costly and require substantial additional work. These costs can be disproportionate where taxpayers have adequate governance systems in place, and explain the low take up of ACAs; refinements could be made to ACA processes to make it less resource intensive and the benefits more accessible, with a view to widening the availability of the process to other taxpayers and taxpayers confirmed benefits in terms of having improved access to ATO staff and obtaining administrative certainty, but these benefits related mainly to uncontroversial issues. Further, where signoffs were qualified with no further action at this time, this did not give sufficient certainty as the ATO could reexamine the issues at a later time. 1.24 The report made the following two recommendations in relation to the administration of ACAs: to make ACAs more widely available to taxpayers through the ATO publicly communicating the expected administrative demands of entering into and maintaining an ACA as well as the expected benefits and to appropriately address the expected increase in ATO workload 41 with respect to ACAs and reduce timeframes and compliance costs associated with ACAs by considering overseas models. The ATO agreed to these recommendations. International experience Organisation for Economic Cooperation and Development 1.25 In July 2013, the Organisation for Economic Cooperation and Development (OECD) examined the relationship between large corporate taxpayers and revenue bodies and published its report, Co‐operative Compliance 40 Inspector-General of Taxation, Review into Improving the Self-Assessment System, August 2012. 41 If ACAs were to become an attractive option there maybe concerns with the ATO’s ability to appropriately deal with the increased demand.