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9 October 2024
In brief
As part of the Australian Taxation Office’s (ATO) engagement with the Top 100 and Top 1,000 taxpayers in relation to goods and services tax (GST), it is introducing a Supplementary annual GST return.
The first return will be for the 2024–25 financial year for those Top 100 and Top 1,000 taxpayers who received a GST assurance rating on or before 30 June 2024. Taxpayers will be notified by the ATO if they need to complete the return and the due date for lodgement but in the meantime the ATO has released the form and detailed instructions so taxpayers can consider how they will prepare.
Who is required to lodge the return?
A GST registered business entity will be required to lodge the annual GST return for the 2024–25 financial year if it has received one of the following on or before 30 June 2024:
- Top 100 GST Assurance Report
- Top 1,000 Combined Assurance Review report with a GST assurance rating; or
- Top 1,000 GST Streamlined Assurance Review
The ATO expects that almost half the Top 100/Top 1,000 population will be required to report for the 2024-25 financial year.
When is the return due to be lodged?
Taxpayers who received a GST assurance review report on or before 30 June 2024 will need to lodge a return annually from the 2024–25 financial year about seven months after their year end. The ATO has set out specific due dates for particular year end taxpayers:
Due dates for the 2024-25 financial years
| 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 |
The return will be legislatively required (as an “additional return” under section 31-20 of the A New Tax System (Goods and Services Tax) Act 1999) which means penalties may be imposed by the ATO for late lodgment or for making false and misleading statements.
The takeaway
The annual GST return will be an important tool the ATO will use to apply its differentiated approach for GST assurance. As it will likely influence the scope and intensity of subsequent GST assurance, taking steps now to ensure that the information reported in your return aligns to the better practice expectations of the ATO should help to reduce the time and resources required for subsequent ATO reviews.
Therefore, we recommend that you:
- Review and action all recommendations made by the ATO in its most recent GST assurance review, including any later interactions.
- Assess whether you meet the criteria to maintain or increase the GST governance rating obtained in the most recent GST assurance review, having regard to the ATO’s GST governance, data testing and transaction guide, and the need for objective evidence to support your assessment.
- Complete the GAT on an annual basis (unless the GAT does not apply to you because you make predominantly input taxed supplies).
- Document any material uncertain GST positions adopted and consider whether any position that could fall into this category should be covered by a reasonably arguable position paper or a private ruling.
- Undertake a review to determine if any material GST reporting errors have been made or material input tax credits referable to earlier tax periods have been claimed. Ensure there are documented position papers as and when such errors or additional credits are identified.
Contact us
If you would like to further discuss this Alert, reach out to our team or your PwC adviser.
Matthew Strauch
Mark Simpson
Andrew Howe
Shagun Thakur
Jeff Pfaff
Mark De Luca
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