The Australian Taxation Office (ATO) has announced updates to its Top 500 Private Groups Tax Performance Program, effective 1 April 2025.

About the Top 500 private groups tax performance program

The Top 500 private groups tax performance program seeks to give the community confidence that Australia’s largest privately owned groups are paying the right amount of tax. It is one of the programs under the Tax Avoidance Taskforce. The program uses a one-to-one approach to collaborative engagements, with the aim to increase willing participation through a focus on prevention rather than correction.

Who is covered by the Top 500 program

The Top 500 private groups program includes private groups:

• with over AUD 500 million net assets, regardless of turnover;
• with over AUD 200 million turnover and over AUD 250 million in net assets;
• that are market leaders or groups of specific interest.

New categories

The top 500 groups have been divided into the following 2 categories:

• significant groups; 
• general groups. 

When full tax assurance is achieved by a group in the general category, they can benefit from a one-year monitoring and maintenance period and streamlined future engagements. ATO will notify groups of their categorisation after the finalisation of their current engagements.

Categorisation is based on several factors, including wealth, market leadership and specific interest groups.

1. Significant groups, which make up approximately one-third of Top 500 groups, have ongoing annual assurance engagements based on the key areas of justified trust. These groups have a significant impact on the tax system, which is reflected in our ongoing assurance and the standard of tax governance needed to achieve justified trust. Significant groups that achieve justified trust will benefit from a 3-year monitoring and maintenance period.

2. General groups, that make up the remaining two-thirds of Top 500 groups, are encouraged to achieve justified trust and benefit from a 3-year monitoring and maintenance period. In addition, general groups that achieve full tax assurance may benefit from a one-year monitoring and maintenance period, irrespective of their tax governance rating, followed by an assurance refresh engagement. The assurance refresh engagement will reconsider some tax issues previously assured. Provided no issues are identified, the group will continue with a further year of monitoring and maintenance.

Groups who are no longer included in the program

Starting from April 2025, the Top 500 program:

• no longer includes private groups with over AUD 250 million turnover, regardless of net asset value;
• turnover threshold has increased from AUD 100 million to AUD 200 million for groups with net assets over $250 million.