The Australian Taxation Office (ATO) is moving to the next phase of its Justified Trust program for GST, expanding the mandatory GST reporting and disclosure obligations for large public and multinational taxpayers in the Top 100 or Top 1,000 programs.
Public and multinational businesses that have reached certain criteria will be required to complete and lodge a new Supplementary Annual GST Return (SAGR), disclosing how matters raised in previous ATO reviews have been dealt with, including any uncertain GST positions adopted, material BAS errors and steps taken to reconcile BAS reporting to financial statements. Essentially, the SAGR will sign-post matters for future review and must therefore be given proper care and attention.
Who needs to lodge the 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 the SAGR. The ATO will notify businesses directly if they are required to lodge this return.
The Supplementary Return is a formal GST Return, meaning that significant penalties can apply if it is not lodged by the due date (see below) or contains false or misleading statements. It should be addressed with proper seriousness.
Purpose of the supplementary return
The return aims to provide the ATO with detailed information on key governance and GST changes during the year, enabling more targeted and less resource-intensive justified trust reviews. It covers several areas, including:
- Actions taken on recommendations and red flags from the most recent GST assurance review.
- Maintenance or improvement of GST governance levels.
- Material business or systems changes impacting the GST control framework.
- Reconciliation between audited financial statements and annualised business activity statements.
- Identification and rectification of material GST errors.
- Claims of material amounts of credits referable to earlier periods
The introduction of the Supplementary Annual GST Return represents a significant shift in the ATO's approach to GST compliance for large businesses. It underscores the importance of maintaining robust GST governance and being proactive in addressing any issues identified during assurance reviews.
Guidance and assistance
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. The ATO has set out specific due dates for particular year-end taxpayers:
| 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 |
Businesses required to lodge the SAGR should:
- Review the ATO's guidance.
- Identify, assess and document the steps you have taken leading from the recommendations and flagged issues from the most recent ATO review.
- Gather objective evidence to support their responses in the return.
- Complete and lodge the return by the specified deadline.
Businesses must download and complete the SAGR form (NAT 75615) and email it to SAGR@ato.gov.au. The ATO may request supporting evidence later.
We’re here to help
For further information or assistance with preparing your SAGR, please get in touch with Grant Thornton’s team of Indirect Tax specialists.
