New Supplementary Annual GST Return for Top 100 and Top 1,000 Taxpayers


At a glance
  • New additional Supplementary Annual GST Return introduced.
  • Applies to taxpayers that received a GST assurance rating through a Top 100 or Top 1,000 assurance review on or before 30 June 2024.
  • Deadline to comply is staggered based on financial year-end, with first reporting due on 21 August 2025 for December balancers.
  • Information will be used to determine whether a differentiated approach can be taken in future reviews.
  • Taxpayers should assess readiness to comply.
  • Penalties can apply for noncompliance.
  • Governance and compliance procedures will need to be updated, and stakeholders will need to be made aware.
  • EY can assist you with an immediate assessment of readiness to comply.

The Australian Taxation Office (ATO) has introduced a new compliance obligation: the Supplementary Annual GST return. This measure targets entities that have undergone GST assurance reviews as part of the Top 100 or Top 1,000 programs and will help the ATO to differentiate their approach for future engagement.

When does it apply?

The ATO will introduce the return for the 2024–25 financial year, for those taxpayers who received a GST assurance report on or before 30 June 2024 with a GST assurance rating. The ATO will notify you directly if you are required to lodge the return. The ATO has published guidance on the return. Lodgements will be staggered, based on financial year end as follows: 

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 ATO will undertake a pilot program to support the implementation of the new return. This will be based on a small number of Top 100 and Top 1,000 taxpayers. The pilot will focus on the clarity and functionality of the questions.

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