Table 2.2: ATO evaluation of ACA effectiveness, interim findings as at August 2014 Evaluation criteria Interim finding Assure appropriate revenue is collected Based on data collected to date, it appears an appropriate amount of revenue is being collected from ACA taxpayers. Influence compliance behaviour Some compliance teams felt that any material change in compliance behaviour maybe due to prior compliance activity. Only one team reported the taxpayer had changed their original position on tax treatment. Other reported behaviour changes were improved record keeping and information sharing regarding major transactions since taxpayers entered into an ACA; and taxpayers asking the ATO for an opinion on transactions before seeking external advice. Improve cost effectiveness for the ATO Mapping compliance FTE usage shows an increased use of resources before entry into an ACA with some tapering off. This is supported by views from ACA teams and senior executive service officers that setting up the ACA agreement is difficult, time consuming and resource intensive for the ATO. Improve ATO understanding of taxpayer’s business and its environment Although ACA teams and SES officers consider they have an improved understanding of the individual ACA taxpayer’s business, there is inconsistent reporting of intelligence. This suggests the ATO is not consistently sharing this knowledge to better understand, detector deal with similar risks that might exist in the wider industry. Supply intelligence Other than procedures for the case management system, there is no consistency in the way the teams gather, share and deal with intelligence. There is ad hoc sharing of information and limited use of the corporate intelligence recording system ATOintelligence Discover. Intelligence gathering, dissemination and reporting needs improvement. Improve risk management in cooperation with taxpayer At the taxpayer level, sound risk management principles appear to be generally adopted, however only half the teams reported communicating directly with operational risk managers. This maybe due to most of the potential risks identified being rated as low. Improve cost effectiveness for the taxpayer There is no evidence to support the proposition that ACAs are more cost effective for taxpayers. There was general acknowledgment that costs increased at the establishment phase, which for some taxpayers maybe offset by indirect savings such as lower costs for seeking external tax advice. Non-ACA taxpayers reported costs to be a barrier. Other data suggests that ACA taxpayers perceive additional benefits that may outweigh any additional costs. Provide the taxpayer with greater certainty The number of rulings for ACA taxpayers increased generally and this was confirmed by teams and SES officers through interviews. However, there are concerns by ACA taxpayers that the ATO sign-off for ACAs may not be legally binding. Taxpayers were also concerned the sign-off is for one year and not the life of a transaction. Management Arrangements ANAO Report No 2014–15 Annual Compliance Arrangements with Large Corporate Taxpayers 51