Tax transparency, certainty, compliance top of ATO’s big business list

In August, ATO deputy commissioner Rebecca Saint outlined the regulator's plans to navigate the tax landscape of larger businesses to bolster its ability to conduct complex investigations across global supply chains and business models.

Speaking at the CPA Tax Forum 2025, Saint highlighted five key areas the ATO believed needed to be navigated in the broader market to deliver better results for taxpayers who had demonstrated high levels of compliance.

The areas that the ATO was set to home in included tax compliance, high assurance, profit shifting, tax certainty and transparency, which would aim to result in an evolved level of confidence, access to data and integration of technology and business compliance.

Saint shared with the Forum audience that the majority of large businesses were meeting their tax obligations, as currently 83 per cent of Top 100 taxpayers held either high or medium overall assurance ratings.

Notably, the proportion of taxpayers achieving an overall high assurance rate now sat at 64 per cent and Top 1000 taxpayers’ ratings also continued to increase, with 89 per cent of them rated as high or medium overall assurance, according to Saint.

“This is a strong indicator of compliance and transparency within the sector. The focus for the ATO over the past 18 months is how we build upon the high levels of compliance demonstrated in our justified trust programs, realising benefits for business and the ATO whilst limiting backslide risk,” she said.

“We have recently re-focused our efforts in the Top 100 program to real time engagement providing tax certainty pre-lodgment of the return. The program has always been intended to work this way, given our focus is on prevention before correction, however our engagement has often been retrospective.”

This was described to be a “strategic pivot” for the ATO as transactions and business changes would be considered closer to the time they occurred, which would provide greater certainty for business and the ATO.

According to Saint, it was imperative that there were high levels of tax compliance in large businesses as it underpinned public trust, ensured fair competition and secured the revenue needed to fund essential services.

“When our largest and most visible businesses do the right thing, it strengthens the integrity of the entire tax system. Tax compliance in the large business sector influences the integrity of the entire tax system and the health of our economy.”

“The ATO continues to have high levels of confidence that most large businesses are meeting their tax obligations. Whilst not the only metric, the tax gap is a key indicator to understand the health of the system.”

It was noted that over the past decade, the ATO had seen steady improvement in voluntary compliance, with large corporates now one of the most compliant segments.

This was attributed by Saint to an increased focus of the Tax Avoidance Taskforce as it was bolstered by law changes that increased the ATO’s ability to tackle base erosion practices. However, the ATO will aim to continue improving the large market gap from current levels to 96 per cent on lodgement and 98 per cent after compliance activity.

Saint said in addition to this, the ATO would look to remain committed to supporting tax certainty for businesses, would work with corporates to understand opportunities to limit duplication across reporting forms and would release two publications, Public Groups findings report and the corporate tax transparency, to continue the improvement on tax transparency.

“Over the coming period, we will continue to have a keen focus on the tax performance of large businesses,” Saint said.

“Ideally, this will deliver better results for those taxpayers that have demonstrated high levels of compliance as well as bolster our ability to conduct complex investigations across global supply chains and business models.”