The ATO’s recent activity in the GST space has been focussed on what they term “GST Streamlined Assurance Reviews”. These are, in effect, comprehensive GST audits. Based on our experience, it is likely that groups who operate in the property industry (an industry the ATO tends to review), and newly formed private GST Groups will be targeted for these “Reviews”.
The information the ATO will review includes:
- Organisational structure – latest GST reporting structure; ABN/CAN of each entity;
- Business activities of each entity;
- Details of acquisitions, mergers and disposals of any business entities within Australia in the review.
- BAS preparation process – a copy of the BAS preparation manual or written procedures including who prepares and reviews the BAS prior to lodgement; details of review and authorisation processes;
- Tax governance and controls framework – Provide the most recent documentation outlining the business tax governance and risk management including tax governance manuals, guidelines or policy available to staff;
- Tax risks flagged to the market – the business is asked to describe its processes to identify tax risks flagged by the ATO (or other bodies) to the market; and
- Significant and new business transactions.
Whilst they will request this information, anything provided prior to an audit and disclosed voluntarily is likely to mitigate any penalties that may be imposed. At this early stage, the ATO says its focus is on information and documents that should be readily available. We take this to mean the ATO will gather information from BAS lodgements, ASIC, ASX and State Revenue to determine which entities it will be reviewing.
If you would like to discuss how we can provide a comprehensive GST risk review for your client(s), please contact Mimi Ngo.