ANAO Report No 2014–15 Annual Compliance Arrangements with
Large Corporate Taxpayers 68
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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