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Australia: Changes to ATO top 500 program

Changes effective April 1, 2025

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April 4, 2025

The Australian Taxation Office (ATO) published changes to the top 500 private groups tax performance program effective April 1, 2025, including:

  • Scope: The program will now include private groups:
    • With over $500 million* net assets, regardless of turnover
    • With turnover exceeding $200 million (up from $100 million) and over $250 million in net assets
    • That are market leaders or groups of specific interest
  • New categories: Groups in the program will be categorized as either “significant” or “general”:
    • Significant groups (approximately one-third of the groups) will have ongoing annual assurance engagements based on the key areas of justified trust. Significant groups that achieve justified trust will benefit from a three-year monitoring and maintenance period.
    • General groups will be encouraged to achieve justified trust and benefit from the three-year monitoring and maintenance period. In addition, general groups that achieve full tax assurance may benefit from a one-year monitoring and maintenance period, irrespective of their tax governance rating, followed by an assurance refresh engagement. The assurance refresh engagement will reconsider some tax issues previously assured. Provided no issues are identified, the group will continue with a further year of monitoring and maintenance.
  • Broadening of provisional justified trust: The provisional justified trust approach will now include all groups that achieve full tax assurance (previously only available to predominately passive investor groups).

*$=Australian dollar


For more information, contact a KPMG tax professional in Australia:

Belinda Cheesewright | belindac@kpmg.com.au

Kristie Schubert | kschubert3@kpmg.com.au

Blake Indian | bindian@kpmg.com.au

Aylin Harapoz | aharapoz1@kpmg.com.au

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