ATO passenger movement data matching: tax and super implications for employers

The program will provide the ATO with greater visibility over individuals travelling into and out of Australia and support its assessment of tax residency, registration, lodgement, reporting and payment obligations within the Australian tax and superannuation systems. The ATO expects to obtain records relating to approximately 115,000 individuals in each financial year from 2026-27 to 2028-29. 

Significantly, the program is not confined to employers with formal global mobility or business traveller programs. It is relevant to any Australian or overseas employer with employees or other workers travelling to or performing work in Australia, including arrangements managed outside Australian payroll, HR or mobility processes. 

This broader visibility increases the risk that previously unidentified PAYG withholding, reporting and Superannuation Guarantee obligations will be detected, particularly where an overseas entity has not registered or lodged required Australian statements.

What information will the ATO receive? 

Under the program, the Department of Home Affairs will provide the ATO with passenger movement information for selected taxpayers, including:

• full name
• date of birth
• arrival and departure dates
• passport information
• visa, residency, lawful status and Australian citizenship information. 

The ATO will electronically match this information against its existing data holdings to identify taxpayers who may require tailored information or compliance activity in relation to their tax and superannuation obligations. The ATO has stated that passenger movement data will not, by itself, be used to initiate automated compliance action.

Why does this matter for employers? 

This program is significantly different in practical effect from the ATO’s existing visa data-matching program. Visa data identifies a person’s permission and conditions to remain or work in Australia. Passenger movement data gives the ATO an independent record of the dates on which selected individuals actually entered and departed Australia. It can therefore identify potential Australian work activity even where the worker is not included in a formal assignment, mobility program or Australian payroll. 

The program may assist the ATO to identify situations where:

• an employee has spent more time working in Australia than the employer’s records indicate
• the employee’s Australian tax residency or income tax position may require review
• PAYG withholding and reporting obligations have not been considered
• Australian Superannuation Guarantee obligations have been overlooked, or
• recurring business travel has developed into a more substantive Australian working arrangement. 

The program will supplement the ATO’s existing visa data-matching program. When passenger movements are considered with visa information, payroll reporting, income tax records and superannuation contribution data, inconsistencies between a worker’s physical presence and the Australian tax and superannuation treatment applied may become more visible. 

This means the risk is not limited to employers with a structured mobility scheme. As previously mentioned, it extends to any employer with workers travelling to or performing duties in Australia, including overseas entities that may not have recognised an Australian registration, payroll, reporting or Superannuation Guarantee obligation.

Short-term business visitors: where is the line for superannuation? 

A common area of uncertainty is whether Australian Superannuation Guarantee obligations arise where an overseas employee visits Australia for a relatively short period. 

An employee may qualify for an income tax exemption under an applicable double tax agreement, depending on the terms of the agreement and the particular circumstances. However, an income tax exemption does not automatically provide an exemption from Australian Superannuation Guarantee. 

There is also no general day-count threshold under the Superannuation Guarantee rules that determines when an inbound employee becomes eligible for superannuation. The analysis instead depends on matters including:

• whether the individual is an employee for Superannuation Guarantee purposes
• whether they are performing work in Australia
• the nature and substance of the activities undertaken in Australia
• the employment and remuneration arrangements
• whether a specific exemption applies, and
• whether the employee remains covered by an overseas social security system under an applicable bilateral social security agreement. 

The ATO’s general guidance confirms that temporary residents may be eligible for Superannuation Guarantee and that eligibility is not determined solely by the amount paid or the length of the employment arrangement.

No single day count determines the outcome 

The key message for employers is that there is no universal point at which a visitor moves from ‘no Superannuation Guarantee’ to ‘Superannuation Guarantee payable’ based only on the number of days spent in Australia. 

A short visit involving conference attendance and internal meetings may present a different result from an equally short visit involving substantive project work. Similarly, repeated short visits may create a different risk profile from a single isolated visit. 

Employers should therefore avoid adopting a blanket policy under which visitors are disregarded until they exceed a nominated number of days. A more supportable approach is to apply an initial risk triage based on:

• the purpose and expected duration of the visit
• whether substantive work will be performed in Australia
• which entity benefits from or directs the work
• how and by whom the employee is remunerated
• whether visits are recurring
• the employee’s home country
• whether a social security agreement applies, and
• whether the relevant certificate of coverage or other supporting documentation has been obtained.

Payday Super increases the timing risk

The introduction of Payday Super from 1 July 2026 increases the importance of inbound employee arrangements being identified promptly.

Where an inbound employee is entitled to Superannuation Guarantee, the contribution must generally be received by their superannuation fund, with sufficient information to allocate it to their account, within seven business days after the employee is paid. Late contributions may result in a Superannuation Guarantee Charge liability.

This creates a practical challenge for employers where:

• the employee remains on an overseas payroll
• payroll is not notified of the Australian visit
• travel data is held separately from HR and payroll systems
• the Australian Superannuation Guarantee position is not considered until after the employee has commenced work
• remuneration is paid before the employer completes its Australian tax and superannuation assessment, and
• the employee does not yet have an Australian superannuation fund.

The first eligible contribution for a new employee or a payment to a new fund may qualify for a longer payment period, but employers should not assume this will resolve delays in identifying the underlying obligation. The ATO’s guidance provides that the first eligible contribution for a new employee or new fund is generally required to be received within 20 business days after the relevant qualifying earnings day.

The consequence is that an employer may have significantly less time to identify, assess and implement an Australian Superannuation Guarantee position than under the former quarterly contribution framework.

Significant Global Entity penalties can multiply quickly

The consequences may be particularly significant where the relevant Australian or overseas employer is a Significant Global Entity (SGE). SGEs are subject to substantially increased failure-to-lodge penalties where a return, statement or other approved form is not lodged on time.

For obligations arising on or after 1 July 2026, the maximum failure-to-lodge penalty for an SGE is $910,000 for a document that is more than 112 days overdue. The applicable amounts are:

The penalty applies separately to each overdue document. Where an overseas group has failed to recognise Australian employer obligations across multiple entities, workers or reporting periods, the potential exposure may therefore multiply quickly. These penalties are separate from any underlying PAYG withholding, Superannuation Guarantee Charge, interest or other administrative penalties that may also arise.

Overseas employers should not assume that the absence of an Australian payroll or formal mobility arrangement means there is no Australian lodgement obligation. SGE status and all potentially outstanding returns and statements should be checked promptly where historical Australian work activity is identified.

Broader ATO visibility over workers in Australia

Passenger movement information provides the ATO with an independent record of when selected individuals entered and departed Australia.

When considered alongside visa information, Single Touch Payroll reporting, income tax records and superannuation contribution data, the program reinforces the need for consistency between an employer’s travel records and the tax and superannuation treatment applied to its internationally mobile workforce.

This is particularly relevant where travel is booked or managed outside formal mobility programs, workers remain on an overseas payroll, or an overseas entity has not established Australian payroll or reporting processes.

What should employers do now?

Employers with any workers travelling to or performing work in Australia should consider whether their processes are designed to:

• identify business travel to Australia before the employee commences work
• distinguish conference attendance and business meetings from substantive work activities
• identify recurring visitors and aggregate travel patterns
• escalate relevant visitors to tax, payroll, HR or mobility teams
• assess PAYG withholding, Superannuation Guarantee and other employment tax obligations
• identify whether relief is available under a bilateral social security agreement
• obtain and retain certificates of coverage and other supporting documentation
• onboard eligible inbound employees within the applicable Payday Super timeframes
• maintain records supporting the position adopted for each visitor.

Historically, some employers may have viewed short-term visits or workers remaining on an overseas payroll as presenting limited Australian employment tax risk. The combination of passenger movement data matching and Payday Super makes that position harder to sustain. Employers now need a timely process to identify anyone performing work in Australia, assess the obligations and remediate historical underpayments or missed lodgements where required.

How can we help?

Grant Thornton can assist employers in reviewing the Australian tax and superannuation implications of internationally mobile employee arrangements, including short-term business visitors, recurring travellers, secondees and longer-term assignees.

Our assistance can include:

• reviewing existing business traveller and global mobility processes
• developing a risk-based framework for assessing short-term visitors
• reviewing PAYG withholding and Superannuation Guarantee obligations
• assessing the availability of social security agreement relief
• supporting Australian payroll and Superannuation Guarantee implementation
• reviewing whether existing processes are operating effectively under Payday Super
• assisting with remediation where historical obligations are identified.

If you require assistance, please reach out to Thomas Isbell, Kimberley Stefan or your usual Grant Thornton adviser.

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