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About the Supplementary annual GST return
We’re working to better tailor our engagement with taxpayers under our Top 100 and Top 1,000 justified trust programs for GST. To facilitate this, we’re introducing the Supplementary annual GST return for large businesses that have received a GST assurance rating through a GST assurance review.
The information provided in your annual return will enable more tailored and less resource investment for justified trust reviews for many taxpayers. The return is straightforward to complete and targeted at understanding key governance and GST changes during the year. Taxpayers who have achieved high levels of assurance are expected to benefit most as they’ve already adopted better practice governance and systems practices.
We’re introducing the supplementary return for the 2024–25 financial year, for taxpayers who received a GST assurance report on or before 30 June 2024 with a GST assurance rating.
We’ll notify you directly if you’re required to lodge the return.
The supplementary return covers:
- how you’ve actioned recommendations, areas of low assurance or red flags outlined by us in your most recent GST assurance review (including subsequent interactions with us)
- whether you’ve maintained or increased your level of GST governance and if you’ve 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
- whether you’ve taken any material uncertain GST positions in the period
- whether you’ve 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.
You should keep objective evidence to support your responses in the return.
Who is required to lodge a supplementary return
Public and multinational businesses that have received a GST assurance rating through a Top 100 or Top 1,000 assurance review are required to lodge a Supplementary annual GST return.
You’ll be required to lodge a supplementary return for the 2024–25 financial year if you 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
- Top 1,000 GST streamlined assurance review.
If you haven’t yet received a GST assurance rating, you’re not required to lodge a supplementary return.
You’ll need to complete a supplementary return starting from the financial year following the financial year you received your GST assurance report.
For example, if you received your first GST assurance rating in a Top 1,000 combined assurance review report issued after 30 June 2024, but before 30 June 2025, you’ll need to complete a Supplementary annual GST return for the 2025–26 financial year onwards.
Examples of lodging a supplementary return
Example 1: GST assurance rating received in September 2024
Titmus Forestry received an initial Top 100 GST assurance report in September 2024, with its first GST assurance rating. Titmus Forestry is an early December balancer.
As Titmus Forestry received the report prior to 30 June 2025, it needs to complete a Supplementary annual GST return for the 2025–26 financial year onwards (that is, for the period 1 January to 31 December 2025).
End of example
If an entity that has been previously assured is no longer a GST reporting entity (that is, no longer lodges business activity statements) but instead is part of a new GST reporting group, then the new GST reporting group must lodge a supplementary annual GST return. This is if the previously assured GST reporting entity (or entities) contributes 50% or more of the GST throughput reported by the new GST reporting group.
Example 2: changes in GST reporting entity
Attia Media Co. received a GST assurance rating in its combined assurance review report in August 2022. In April 2024, Attia Media Co. ceased being a GST reporting entity as it was acquired by another entity and is now a member of a new GST group. Attia Media Co. contributes 75% of the GST throughput reported by the new GST group, Saniel Communications.
Despite Saniel Communications not having had an initial GST assurance review itself, the ATO advises Saniel Communications that it will need to lodge a Supplementary annual GST return for the 2024–25 financial year onwards. This is because Attia Media Co. contributes over 50% of the GST throughput reported by Saniel Communications.
End of example
When the supplementary return is due
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, according to the due dates shown in Table 1.
Table 1: Due dates for the 2024–25 financial years
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Financial year end
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Due date
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December 2024
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21 August 2025
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January, February, March 2025
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21 November 2025
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April, May, June 2025
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21 February 2026
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July, August, September 2025
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21 May 2026
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October, November 2025
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21 August 2026
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The Supplementary annual GST return is a further return that we require certain taxpayers to lodge under Division 31 of the GST Act. If you need to lodge the supplementary return, you’ll receive a notice under section 31-20 of the GST Act to lodge the return by the specified due date.
Division 31 enables us to require taxpayers to lodge a fuller or further GST return for a tax period or a specified period. It enables us to require information to be provided relating to the tax period to which the return relates, or one or more preceding tax periods, or to both.
The Supplementary annual GST return has a due date that aligns with an existing return due at least 7 months after the end of the financial year.
For instance, for June balancers, the 2024–25 Supplementary annual GST return will be an additional return for the January 2026 period, due by 21 February 2026. You will need to provide information about the period 1 July 2024 to 30 June 2025.
The supplementary return does not replace any other GST return required. This return has no effect on the due dates for any other returns. It does not affect the 4-year entitlement period to input tax credits under Division 93 of the GST Act, in any way.
Penalties can apply if you fail to lodge the supplementary return on time.
The information provided in the supplementary return will help us:
- assess the extent to which we have confidence that GST has been correctly reported
- determine the level of ongoing investment in GST governance.
Generally, our future engagement with you will depend on a number of factors, including:
- the level of assurance obtained in our most recent GST assurance review
- our monitoring and analytics during the periods between assurance reviews
- the information provided in your return.
The return collects information relevant to your continued investment in GST governance and correct reporting. It includes the work you’ve undertaken to address previous ATO recommendations or areas of low assurance or red flags, and whether you have completed the GST analytical tool or similar reconciliation for the period.
We’ll also use the information provided to identify and monitor GST risks. We’ll differentiate our approach where we identify specific issues that require further engagement with you.
Taxpayers in the Top 100 program
We complete an initial Top 100 GST assurance review for each Top 100 taxpayer and continue annual reviews until overall high or medium assurance is attained.
Once a taxpayer has attained an overall medium or high level of assurance in a Top 100 GST assurance review, they can expect tailored engagement. We review on a periodic basis at least once every 4 years, taking a monitoring stance during the intervening 3-year period. We may conduct targeted assurance activities during this time.
We use the information you provide in the Supplementary annual GST return for Top 100 taxpayers to:
- monitor your GST disclosures and outcomes in the intervening 3 years
- inform the scope and intensity of our GST assurance reviews, including refresh reviews.
The return also provides information for the refresh review period that is relevant to each of the 4 focus areas under justified trust. We’ll use this information, in conjunction with our earlier assurance review and what has since been disclosed in real time, to target our focus on the key areas where we need to refresh our assurance base.
Our Top 100 Pre-lodgment disclosure framework sets out our existing expectations for real-time disclosures by Top 100 taxpayers. If you disclose something in real time that needs to be included in your Supplementary annual GST return, you can provide a brief explanation in the return and refer to the date of the prior disclosure for further context.
Example 3: taxpayer in the Top 100 program
Layoun Minerals is a Top 100 taxpayer that has had a GST assurance review and receives an overall high assurance rating and a Stage 2 governance rating. There were no areas of low assurance or red flags in the assurance report.
Our assurance report recommends that Layoun Minerals:
- create a procedure document in relation to issuing recipient created tax invoices
- implement a documented procedure to undertake the GST analytical tool (GAT) or similar reconciliation on an annual basis to understand variances between their financial statements and GST reporting
- evidence independent testing of their GST control framework.
Layoun Minerals actively implements our recommendations. It also makes real-time disclosures when applicable in accordance with the Top 100 Pre-lodgment disclosure framework.
When completing the Supplementary annual GST return for the 2024–25 financial year, Layoun Minerals provides the following responses:
- Section B – there were no outstanding actions in relation to recommendations or areas of low assurance or red flags from its most recent GST assurance review (including subsequent ATO interactions) as it has
- implemented a procedure document for recipient created tax invoices
- a documented process to undertake the GAT annually
- conducted the first phase of internal controls testing in line with its testing plan, with an independent tester conducting the testing of some specific controls and providing a report outlining the findings.
- Section C – during the period the return covers, it considers it meets the criteria to maintain the GST governance rating given in the most recent GST assurance review, based on the criteria set out in our GST governance, data testing and transaction testing guide. There have not been any material business changes or material systems changes that impact its GST control framework since the earlier assurance review.
- Section D – it had completed the GAT for the period the return covers with the following rates provided
- effective GST rate on sales of 10.03%
- effective GST rate on expenses of 9.72%
- net effective GST rate of 9.84%.
It considers that the remaining variance could only be resolved through a transactional-level analysis.
- Section E – it did not take any material uncertain GST positions in the period the return covers.
- Section F – during the period the return covers, it has not identified any material GST reporting errors or claimed material input tax credit amounts referable to earlier periods.
Layoun Minerals retains objective evidence to support its responses.
Layoun Minerals has a refresh GST assurance review of the 2024–25 financial year.
We take a tailored approach in determining the scope and intensity of the refresh review. We leverage existing information, evidence and knowledge from our earlier assurance review, in combination with the information provided in Layoun Minerals’ Supplementary annual GST return for the refresh period and any real-time disclosures.
The information indicates that Layoun Minerals has maintained a high level of GST compliance and governance. This enables us to reduce the scope and intensity of the refresh review.
Layoun Minerals has already completed the GAT and can readily provide the objective evidence used to support its calculations.
When considering all the relevant information, including the Supplementary annual GST return, we determine that there will be no requirement to conduct comprehensive data testing in the refresh review.
End of example
Taxpayers in the Top 1,000 program
Under our differentiated approach to combined assurance reviews, we’ll assess the responses to the returns to determine the level of intensity for your next GST assurance review. This may result in a less intensive GST assurance review, or we may decide a GST assurance review is not required, where:
- you have obtained an overall medium or high assurance rating for GST and a Stage 2 or Stage 3 GST governance rating in your most recent assurance review, with no unresolved ATO or client next actions
- the information you provide in the return enables us to maintain confidence that your investment in GST governance is maintained and that GST is correctly reported.
Taxpayers who obtained an overall low GST assurance rating or a Stage 1 GST governance rating will continue to be assured as part of their combined assurance review, however our review will be tailored based on the assurance already attained and the responses provided in the return.
For taxpayers with significant systems changes (for example, implementing a new IT system) since their most recent GST assurance review, generally we would need to consider the impacts of these on GST governance through our assurance programs. There may also be taxpayers where specific engagement is required due to GST risks in their business.
We may take a tailored approach to reviewing objective evidence to support responses in the return as part of a combined assurance review. This approach will vary based on the assurance previously attained and the responses in the return. For example, this may include reviewing evidence where a taxpayer indicates it has:
- increased a rating to Stage 3 for governance
- addressed recommendations in relation to a specific risk identified in the earlier assurance review
- GAT workpapers.
Example 4: taxpayer in the Top 1,000 program
Timlin Manufacturing is a Top 1,000 taxpayer that has had a combined assurance review and received an overall high GST assurance rating and a stage 2 GST governance rating. There were no areas of low assurance or red flags in the assurance report.
Our assurance report recommended that the taxpayer:
- evidence independent testing of their GST control framework
- document a process to periodically review whether it exceeds the financial acquisitions threshold
- implement a documented procedure to undertake the GST analytical tool or similar reconciliation on an annual basis to understand variances between their financial statements and GST reporting.
Timlin Manufacturing has actively implemented our recommendations from its assurance review.
When completing the Supplementary annual GST return for the 2024–25 financial year, Timlin Manufacturing’s responses were:
- Section B – there are no outstanding actions in relation to recommendations or areas of low assurance or red flags relating to its most recent GST assurance review (including subsequent ATO interactions).
- Timlin Manufacturing has implemented documented procedures to undertake the GST Analytical Tool (GAT) on an annual basis and has introduced documented processes to regularly review whether the financial acquisitions threshold has been exceeded.
- Timlin Manufacturing has commenced some controls testing in line with its testing plan, however it will not complete the testing until 2025–26 because the testing occurs over a 3 to 5-year rolling audit period.
- Section C – it considers it meets the criteria to maintain the GST governance rating obtained in the most recent GST assurance review. That is, it considers it has maintained a Stage 2 rating, based on the criteria set out in our GST governance, data testing and transaction testing guide.
- Section D – it has completed the GAT and considers that all variances can be explained. The following rates were provided:
- effective GST rate on sales of 9.96%
- effective GST rate on expenses of 9.94%
- net effective GST rate of 9.82%.
It considers that the remaining variance can reasonably be explained by timing differences.
- Section E – it has not taken any material uncertain GST positions in the period the return covers.
- Section F – it has not identified any material GST reporting errors or claimed material input tax credit amounts referable to earlier periods.
Timlin Manufacturing retains objective evidence to support the responses.
Based on the information provided in the return, we were able to assess Timlin Manufacturing’s GST compliance position and determine that it has actioned our recommendations and the responses provided us with confidence that the level of investment in GST compliance has been maintained.
If Timlin Manufacturing is selected for a combined assurance review in the 2024–25 financial year, we would expect to either:
- not undertake a GST assurance review as part of the combined assurance review
- take a tailored approach to reviewing objective evidence to support responses in the return.
End of example
Completing and lodging the supplementary return
To get a copy of the return, go to Supplementary annual GST return 2025. You can also read Instructions to complete the Supplementary annual GST return 2025.
Email the completed Supplementary annual GST return to SAGR@ato.gov.au.
If additional lodgment methods are available, we’ll let you know when we issue your notice to lodge.
You should have objective evidence to support your responses in the return. However, you do not need to provide any documentation when lodging your return. We may ask you for supporting evidence later.
If you have any questions about the Supplementary annual GST return, you can email us at SAGR@ato.gov.au.