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Supplementary annual GST return
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  • 7 minute read
  • 09 Oct 2024

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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 for the 2024–25 financial year. This will be relevant to those Top 100 and Top 1,000 taxpayers who received a GST assurance report on or before 30 June 2024 with a GST assurance rating.

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.

In detail

What the return covers

A copy of the return has been made available from the ATO website. The return has 12 questions and covers:

  • how you have actioned ATO recommendations, areas of low assurance or red flags outlined your most recent GST assurance review (including subsequent interactions with the ATO)
  • whether you have maintained or increased your level of GST governance (e.g. undertaken controls testing) and if you have had any material business or systems changes that impact your GST control framework since your last GST assurance review
  • the reconciliation between your audited financial statements and your annualised business activity statements (the GST Analytical Tool (GAT))
  • whether you have taken any material uncertain GST positions in the period; and
  • whether you have identified any material GST errors in the period and how these have been rectified, and whether you claimed any material amounts of credits in the period that were referable to earlier periods (e.g. due to a change in apportionment).

“Material” for the purposes of the last two points has been defined for these purposes as being GST at issue of $250,000 or more for Top 1,000 taxpayers or $500,000 of more for Top 100 taxpayers.

Further information on the questions, including examples, is available from the ATO website.

Objective evidence should be retained to support responses provided in the return.

The ATO will use the information in the return to monitor GST risks and differentiate its approach for subsequent reviews. Whilst the returns themselves are not expected to result in compliance activity, that could depend on the answers (particularly regarding material uncertain GST positions).

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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.

An annual GST return is not required if the entity has not yet received a GST assurance rating. However, once the GST assurance rating has been received, an annual GST return will be required to be lodged starting from the financial year following financial year the GST assurance rating is obtained. Affected entities will be notified by the ATO if they need to lodge the return.

At present, taxpayers outside the Top 1,000 population will not need to lodge an annual return.

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

Partner, Tax Reporting and Innovation, PwC Australia

+61 408 180 305

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Mark Simpson

Partner, Tax, Sydney, PwC Australia

+61 (2) 8266 2654

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Andrew Howe

Partner, Global Tax, Sydney, PwC Australia

+61 414 641 438

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Shagun Thakur

Partner, Perth, PwC Australia

+61 8 9238 3059

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Jeff Pfaff

Partner, Corporate and Global Tax, Brisbane, PwC Australia

+61 401 222 696

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Suzanne Kneen

Partner, Tax Reporting and Innovation, Melbourne, PwC Australia

+61 434 252 344

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Mark De Luca

Partner, Tax Reporting and Innovation, Sydney, PwC Australia

+61 433 197 797

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