Largest taxpayers must now annually detail unresolved GST maters; control issues; risks; and errors
The Australian Taxation Office (ATO) is looking to strengthen GST compliance at the largest taxpayers with the introduction of a new annual GST return. It requires disclosures and reporting reconciliations on GST transactions. The information provided in the annual return will enable the ATO to undertake more targeted and less resource intensive justified trust reviews for many taxpayers.
Due dates for GST annual return
The annual return will be required to be filed as follows:
| Financial year end | Due date |
|---|---|
| December 2024 | 21 August 2025 |
| January, February, March 2025 | 21 November 2025 |
| April, May, June 2025 | 21 February 2026 |
| July, August, September 2025 | 21 May 2026 |
| October, November 2025 | 21 August 2026 |
Primary objectives
Key objectives include sustaining “justified trust” in GST compliance during monitoring, identifying GST risks (e.g., uncertain positions), and refining the scope of future assurance reviews (such as determining the need for data testing). Taxpayers must disclose five core areas:
- Outstanding Action Items: Any unresolved GST issues or unaddressed ATO recommendations from prior assurance reviews.
- GST Governance: Whether the taxpayer’s governance rating has been maintained or improved, and any significant changes to business or systems impacting GST controls.
- Reconciliation: A reconciliation of audited financial statements with the Business Activity Statement (BAS) using the GST Analytical Tool (GAT) or an equivalent, explaining any variances.
- Material Uncertain GST Positions: Disclosure of any uncertain GST positions, where outcomes are not clearly correct, including those with potential shortfalls exceeding AUD 250,000 or AUD 500,000 depending on the taxpayer category or AUD 500,000 in GST for a Top 100 taxpayer.
- Material GST Errors or Credits: Reporting of material GST errors or input tax credits claimed in a later BAS, with thresholds similar to uncertain positions.
