1.1 The Inspector-General of Taxation (IGT) welcomes the opportunity to make a submission to the House of Representatives Standing Committee on Tax and Revenue's (Committee) Inquiry into Taxpayer Engagement with the Tax System (Inquiry).
1.4 Within this context, scrutineers, such as the IGT, play a critical role in fostering community trust and confidence in the tax system which in turn enhances voluntary participation and efficient administration. Taxpayers and their advisers take comfort that an independent agency can investigate their complaints or broader systemic issues, provide impartial views and make recommendations for improvement. The availability of such avenues significantly contributes to the perception of fairness in the tax system as a whole.
2.1 There is currently no universally accepted definition of the 'cash economy'. It varies from jurisdiction to jurisdiction and may be referred to by a number of different names, including the 'hidden economy', 'non-observed economy' (NOE), 'underground economy' or 'black economy'.
…is an estimate of the difference between what the ATO collects and the amount that would have been collected if every taxpayer was fully compliant….
2.8 The ATO's recent approach to measure tax gap seems to align with processes adopted by other revenue authorities, such as the United Kingdom's (UK) Her Majesty's Revenue and Customs (HMRC). HMRC, who has been measuring tax gap for some time, publishes an annual report of its tax gap analysis. For the 2014-15 financial year, HMRC reported that the tax gap attributable to the hidden economy was £6.2 billion11 which represents approximately 17 per cent of the total tax gap of £36 billion.
The cash and hidden economy affects all Australians. It affects us by reducing the amount of money available to fund community services such as health, education and other government programs.
Honest businesses face unfair competition when others don't correctly record and report all their income and expenses.
prove who was responsible in cases of poor work quality.
Efforts are made to evaluate the impacts of individual risk treatments and/or the overall strategy.
Comprehensive industry benchmarking, coupled with leveraging via tax professionals, media engagement and automated targeting of large numbers of taxpayers (Australia).
Industry-based withholding/third party reporting regimes (Ireland and Canada).
Increased controls over cash transactions (Netherlands, Spain, and Sweden).
Increased record-keeping controls for employees in high-risk industry sectors (e.g. restaurants and hairdressing) (Sweden's staff ledgers).
Initiatives aimed at reducing the use of cash transactions (Norway and Turkey).
The use of monetary incentives to encourage proper record-keeping and deter unrecorded cash payments (Canada's and Norway's home renovation tax credit, Korea's lottery and incentive for obtaining receipts).
Increased revenue body use of suspicious transactions reports collected by a separate government agency (Australia and France).
2.13 Turning to approaches of comparable jurisdictions, in 2007, the United States' (US) National Taxpayer Advocate (NTA) undertook a review of the revenue forgone because of the cash economy. The report indicated that the difference between the tax payable and the amount voluntarily paid by taxpayers was approximately US$345 billion in 2001, with US$100 billion per year being attributable to the cash economy.17 The major recommendation from the NTA was that a Cash Economy Program Office should be established18 as a means of implementing and coordinating the overall strategies of the Internal Revenue Service (IRS) in this area. It appears that the IRS declined to do so and the NTA had expressed concerns that without such an office, 'ad hoc measures will not get the job done'19.
2.15 In 2016, the HMRC published a number of consultation papers in relation to proposals to assist in tackling the cash economy.21 These new proposed strategies follow on from earlier initiatives in which the HMRC made use of extensive educational campaigns to improve taxpayer compliance behaviour.22 The current proposed strategies are three-pronged and include extending the data-gathering powers to 'money service businesses',23 the need for new penalties and sanctions24 as well as conditional registration.25 The latter point requires 'tax registration as a condition of access to some essential business services or licences'.26 As part of its strategy, the HMRC is also seeking to identify points at which businesses tend to enter the cash economy by failing to register for certain taxes (such as Value Added Tax when certain thresholds are met) and making it as easy as possible for taxpayers to register.
2.16 In 1998, the Government stated that the 'taxes and collection systems allow too much scope for taxpayers to participate in the cash economy'.27 The Government at the time proposed and implemented a number of strategies including the introduction of the Australian Business Number (ABN) as a single business identifier for dealing with the whole-of-government, simplifying payment and reporting systems (the PAYG system) as well as other law and administrative changes to promote certainty and make compliance simpler and fairer.28 The improvements included the requirement for all businesses to register for ABNs with the consequence that unregistered businesses would have a significant proportion of their payment withheld by trade partners and remitted to the ATO.
compliant taxpayers may become less compliant where they feel that the underground economy is not being properly addressed and that, as a result, they bear an unfair share of the tax burden.
2.24 The IGT has previously undertaken two reviews which are relevant to the ATO's approach to the cash economy.
2.28 The IGT supports the ATO's current work to measure the scope and impact of the cash economy and it is pleasing that the ATO has undertaken some work to measure the tax gap. An important factor in this task would be for the ATO to identify which component of the tax gap is in fact attributable to the cash economy and which components are due to other reasons, such as lack of knowledge of tax laws or taxpayers adopting positions that are different to the ATO's view of the law. In doing so, the ATO could engage with the academic community as well as revenue agencies of comparable jurisdictions, such as the HMRC.
2.29 In respect of enforcement and compliance activities, as mentioned above, the ANAO has found the ATO's strategies and activities to combat the cash economy are generally working well. In addition, the ANAO has noted that more can be done to measure the effectiveness of help and education programs.
2.32 The IGT is also looking forward to the findings and recommendations of the Committee as well as the Black Economy Taskforce. The IGT would be pleased to offer assistance and expertise in relation to any identified measures to combat the significant risks posed by the cash economy.
3.1 Generally, taxpayers interact with the tax and superannuation systems in order to meet their statutory obligations such as registering, reporting, withholding and paying their tax liabilities. Taxpayers may choose to do so through intermediaries, such as tax practitioners, or directly through services and channels provided by the ATO.
3.2 Tax practitioners, including lawyers and business activity statement (BAS) preparers, have played a fundamental role in the tax system particularly since the shift from full assessment to self assessment in 1986. The shift to self assessment transferred to taxpayers the responsibility of applying the tax laws to their affairs with the consequence that incorrect application would result in taxpayers being exposed to additional primary tax, penalties and interest.
3.5 The Productivity Commission has noted that 'small businesses are much more likely than large businesses to rely on third parties, including industry and professional associations and intermediaries such as tax agents, to receive information on regulatory requirements.'53 This should not detract from the important role that tax practitioners across all market segments, including the large business market, play in the effective administration of the tax system.
3.8 In addition to the traditional tax intermediaries noted above, there are increasingly new players providing services and products within the tax sphere. Most notable of the new intermediaries are software developers whose products are being developed to feed directly into ATO systems to align with initiatives, such as Standard Business Reporting (SBR) and Single Touch Payroll (STP). The customer support from these providers and the associated cost will no doubt influence the experience of taxpayers and their advisers in managing their affairs.
3.9 Similarly, as the ATO continues to roll out technology to enable taxpayers to effectively manage their own tax affairs, sufficient take-up depends on ready access to adequate hardware, software and robust internet connections. Accordingly, other software and hardware developers as well as telecommunications entities also necessarily play an important role.
managing business reporting and transactions via the Tax Agent Portal, BAS Agent Portal and Electronic Lodgment Service (ELS).
3.19 The IGT supports the ongoing use of technology where such technology makes it easier and cheaper for taxpayers to effectively interact with the system to discharge their obligations. However, notwithstanding the increased use of technology and digital channels, it is necessary to appreciate that tax practitioners and other intermediaries continue to play a crucial role in the tax system. The ATO's ongoing service delivery should not detract or dissuade taxpayers from seeking independent tax and legal advice on their tax affairs. The ATO cannot and should not be the sole source of advice for taxpayers.
3.21 The ATO has been working to improve its relationship with tax practitioners as it is critical for the efficient administration of the tax system. Furthermore, the IGT has announced that, in response to a request from the Commissioner, a review will be conducted into the future role of the tax profession. The aim of the review is to consult widely with tax practitioners, taxpayers and their representative bodies as well as with the ATO and TPB to ensure all major issues are addressed and to chart the best way forward for the efficient and effective administration of the tax system. In particular, the increased use of digital technology and ATO service delivery initiatives will be explored.
3.24 Technological developments may also necessitate greater reliance on third party software providers in future. Whilst the IGT may tangentially consider the role of these new intermediaries as part of the above review, the Committee may also wish to examine how they are currently interacting with the ATO and the community in providing their services and any improvements that may be required.
3.25 In addition to the concerns raised by tax practitioners about digital delivery of services, the IGT has also received complaints from taxpayers directly. These concerns have tended to focus on the difficulties of some taxpayers to use such channels for service delivery. For example, one case concerned a local church's inability to engage with the SuperStream system electronically due to the remoteness of their location and their limited access to the online services. Other complaints have noted the limited availability of paper forms and guidance and the channels through which these may be requested. The IGT has also received similar feedback through submissions made to the development of his Work Program for 201781.
3.26 As noted above, the ATO has also received feedback on the need for alternatives to digital interaction in certain cases and has published information on its website which outlines the types of services it provides for people with a disability.82 Through the IGT's complaints handling function, we have also become aware that ATO officers seek to assist taxpayers where they can by, for example, providing printed copies of sections of the website and other digital information.
3.29 In the light of the NTA's research in the US, taxpayer requests to the IGT and the ATO for alternatives to digital interactions as well as the potential for technological outages, the Committee may wish to consider whether there is a need to formally establish alternative methods of interaction with the ATO, at least as a contingency measure.
3.30 In relation to the recent ATO outages, the IGT has been informed that the ATO is undertaking a number of internal reviews into their causes and consequences. At the same time, it has also commissioned PwC to externally review the matter.87 To the extent that outages or disruptions continue and concerns persist, the IGT will consider whether to independently investigate the matter.
3.31 Finally, in relation to issues concerning compliance costs, the IGT believes that a greater understanding of the costs imposed on all taxpayers when interacting with the tax system would assist to inform both tax policy design and administrative practices. The IGT has previously supported the idea of an independent body, such as the Productivity Commission, 'undertaking a study to measure tax related compliance costs and their impact on the administrator, the taxpayer, tax practitioners and the Australian economy as a whole.'88 Such a study would also be useful in determining whether the increased use of digital interaction has lessened the compliance burden for the various taxpayer groups.
4.1 The previous chapter of the IGT submission examined a number of ways in which taxpayers interacted with the tax system, including through electronic and digital channels offered by the ATO. The use of electronic and digital channels is supported internally by the ATO's own Information and Communication Technology (ICT) platform.
4.4 The IGT has previously examined a number of ATO initiatives aimed at enhancing its technological services through data collection and use as well as the ATO's communications. These discrete initiatives are separately discussed below and include the IGT's view and observations.
4.5 Each year, the ATO receives large amounts of taxpayer data from a number of third party sources including from other government agencies, financial institutions and foreign revenue authorities. Some are required to be provided by legislation whilst others are provided by less formal means.91 The ATO validates and refines such data before comparing them to taxpayers' reported information to identify potential discrepancies. The cases which contain discrepancies undergo a selection process to identify those suitable for further scrutiny and potentially lead to audits.
4.6 In addition to using its data holdings to identify potential discrepancies in reported income, the ATO also uses it to pre-fill electronic income tax returns where the data can be appropriately matched to a specific taxpayer. Pre-fill is designed to improve accuracy and ease the preparation of tax returns. Information that may be pre-filled include items such as salary and wages, taxes withheld by employers and bank interest.
reliability and accuracy – in some instances, pre-filling information may not be reliable. However, the ATO website does caveat that taxpayers bear the onus of confirming the veracity of any information reported in their tax return.
4.14 Some submissions to the IGT's 2017 Work Program have suggested that the ATO could do more to bolster its pre-filling program. One example was collecting data on deductible charitable donations and pre-filling those as a means of both assisting taxpayers and fostering greater giving. Any such moves to expand the pre-filling program will necessarily require the ATO to have robust processes for obtaining the data. As mentioned above the ANAO has asserted that it is not sufficient to simply rely on the good will of data providers. Where necessary, the ATO may require legislative changes mandating the provision of relevant data.
4.15 However, in the above review, the IGT has noted that although the use of data is helpful, where the ATO requests large amounts of information which are ultimately not used, this creates costs for the third party providers and administrative costs for the ATO.107 To reduce these impacts the IGT recommended that the ATO needs to identify the areas in which its data matching work is effective and those in which it is less effective.108 Moreover, the IGT also recommended that the ATO work closely with potential data providers to consider their 'natural business systems' and the options available to the ATO to support or subsidise any necessary changes to improve the provision of data.
4.16 The ATO has recognised the importance of data collection and use and is implementing a strategic Smarter Data program to make smarter, unified use of data to improve decisions, services and compliance. It is a whole-of-ATO approach to risk assessment, intelligence, analytics, data management and technology. This framework will seek to deliver value by 'making it easy to comply and hard not to' in line with the ATO's reinvention program.109 The IGT has not had an opportunity to review this program and it may be an area which may benefit from the Committee's consideration.
4.17 Whilst the ATO continues to improve the accuracy of the pre-filled information, it is important that taxpayers and their advisers do not rely solely on it in completing their tax returns. Any inaccuracies are not desirable for the integrity of the system and may also result in subsequent compliance action which would impose an additional burden on both the ATO and the taxpayer.
4.19 The Committee may wish to consider the extent to which pre-filling of tax returns should be further progressed in Australia and the legislative and administrative means which would facilitate such a goal.
4.23 In line with the SBR initiative, the ATO intends to upgrade its current online platform, including the ELS through which tax practitioners lodge their clients' returns. As a result of this development, practitioners will need to upgrade their current practice management software to one that is SBR-enabled. Taxpayers will also be encouraged to implement SBR-enabled software. In both cases, initial cost outlays are expected for both tax practitioners and their clients.
4.24 The IGT considered SBR in his 2015 review into services and support for tax practitioners.117 It was found that stakeholders have generally supported the SBR's aim of streamlining reporting requirements for government departments such as the ATO.118 However, at the time the review was conducted, the main impediment to SBR's success was its low adoption rate by businesses and tax practitioners.119 To address the issues related to SBR-adoption, the IGT set out a number of steps that the ATO could take.
4.29 The Committee may wish to further examine the ATO's implementation of SBR, given the passage of time since the ATO commenced this task and the above IGT review.
4.30 STP aims to 'cut red tape' for employers by 'simplifying tax and superannuation reporting obligations'.124 Employers who are required to comply with STP requirements will need to report PAYG withholding and superannuation guarantee (SG) information to the ATO every payroll cycle.
4.31Employers with 20 or more employees will be required to comply with STP requirements from 1 July 2018.125 However there are options for early uptake from 1 July 2017.126 Employers who are required to comply with STP will incur some initial set-up costs in either purchasing new software, upgrading existing software or using the services of an external intermediary to comply with their obligations.
4.33 In addition to exempting employers with fewer than 20 employees, the STP legislation allows the Commissioner to exempt particular employers or classes of employers from meeting those requirements in appropriate circumstances.
4.35 There are clear benefits in the introduction of STP, both for the reduction of reporting burdens on employers as well as enhancing the availability of timely data to enable the ATO to act quickly and address any compliance risks in relation to PAYGW and SG as they arise.
4.38 In addition to using its ICT platform to assist taxpayers, the ATO has also made use of digital communications, including social media channels, as a means of quick and cost effective communication with taxpayers.
4.45 The IGT recognises that new means of communication provide different opportunities for the ATO to engage directly with the community at very low cost. However, care must be taken to respect the role of intermediaries, such as tax practitioners. As noted in the previous chapter, the advent of platforms such as myTax and myGov has caused concerns for tax practitioners who feel they are being circumvented. This is particularly true in instances where taxpayers who rely on tax practitioner services are receiving correspondence directly from the ATO through the myGov inbox without the tax practitioner being necessarily informed.
4.46 The IGT has received a number of complaints on the above issue and has facilitated conversations between the ATO and some affected tax practitioners to ensure appropriate outcomes are achieved and to foster a closer working relationship between the two parties.
4.48 In respect of using social media as a means of detecting non-compliance, whilst the IGT believes that the ATO should use all information at its disposal to combat non-compliance, care must be taken to ensure that information relied upon is accurate and verifiable and that privacy laws are not breached. This is particularly important in the context of social media or other uncontrolled sources of information in which there is significant scope for inaccuracy and exaggeration.
4.49 The Committee may wish to consider any further use of digital communications, particularly social media, by the ATO and in doing so address any security and privacy concerns.
4.50 In addition to the above, the IGT has also examined other ICT improvements that the ATO could implement to assist taxpayers. In the 2015 review into services and support for tax practitioners, the IGT recommended that the ATO increase its use of modern modes of communication.144 Other recommendations considered the publication of practical online user guides in relation to certain ATO platforms, simplifying proof of identity through the use of unique identifiers or voice recognition and developing a 'web chat functionality' to provide tax practitioners with useful information.
4.51 The ATO has undertaken some work in relation to the above. For example, it is making some use of voice recognition for taxpayers145 and has developed a 'virtual assistant' on its website called 'Alex' that 'understands conversational language and can clarify what you want and answer your questions.'146 The IGT has not had opportunity to examine the effectiveness of these new technologies. The Committee may wish to consider current ATO endeavours in this regard and explore any additional measures to enhance its service delivery to the community.
enabling people to make 'better choices for themselves'.
establish links between the APS and the behavioural economics research and practitioner community, here and overseas.
The key outcomes of the BRP are to understand the drivers for the accumulation of tax debt by small businesses and subsequently develop better services and compliance strategies which, amongst other things, encourage willing payment of taxes and prevent debt accumulation.
Some of the key areas the project will consider include how small businesses make decisions concerning the payment of tax debt and relative payment priorities as well as how small business taxpayers form views about the behaviour of others. Furthermore, key characteristics of taxpayers likely to fall into tax debts were investigated, including the type of taxpayer entity, number of employees, turnover, the age of the entity and the industry within which they operate. The project will also consider the ATO's role in the prevention of tax debts and specifically whether its interventions 'promote, limit or prevent tax debt'.
Toward the end of this review, the ATO advised that they have commenced working with the IRD to compare the results of their respective research to provide 'new ideas on how to prevent the accumulation of aged debt by small businesses'. Additionally, the ATO expressed an intention to strengthen its corporate research capability more broadly to provide evidence which supports improved decision making.
Arrive at a constructive solution that results in a greater likelihood of resolving the debt, such as requesting larger initial payments with next payment within a week.
One of the key learnings from international experience is that public sector agencies need to be mindful that behavioural change policy goals have to be reasonably congruent with a particular society's views on the right balance between individual responsibility and government responsibility. These views vary according to policy area and over time.
5.11 The IGT has for many years championed the increased use of behavioural insights in various aspects of tax administration and much of the work that the ATO has undertaken in this area has been as a result of IGT reviews. For example, in the Review into the ATO's compliance approach to individual taxpayers – income tax refund integrity program (ITRIP), the IGT considered applied research from the UK BIT. Having regard to that research, recommendations were made for the ATO to assess the effectiveness of the ITRIP letters to generate the intended behavioural response from individual taxpayers through the use of RCTs in correspondence design.159 The IGT also reiterated that support through a range of other reviews including those examining data matching,160 the ATO's use of risk assessment tools,161 debt collection,162 excess contributions tax163 and penalties164.
5.12 In addition to the above work, the IGT believes that the ATO could further benefit from insights arising out of projects conducted by BETA with other comparable service delivery agencies and learnings from the BIU and BIT. In respect of implementing significant new changes, the ATO should continue to make use of RCTs which have been strongly supported by the BIT.
1 Jo'Anne Langham and Neil Paulsen, 'Effective engagement: Building a relationship of cooperation and trust with the community' (2015) eJournal of Tax Research 13:1, pp 378-402 at 378.
2 Australian Taxation Office (ATO), 'Our evolving approach to taxpayer engagement' (Speech delivered to the Tax Institute of Victoria Fourth Annual Forum, 5 October 2016) <www.ato.gov.au>.
3 House of Representatives Standing Committee on Tax and Revenue, 'Inquiry into Taxpayer Engagement with the Tax System' (25 November 2016) <www.aph.gov.au>.
4 ATO, 'The cash and hidden economy' (2 November 2016) < www.ato.gov.au>.
5 Australian Bureau of Statistics, '5204.0.55.008 – Information paper: The Non-Observed Economy and Australia's GDP, 2012' (18 September 2013) <www.abs.gov.au>.
6 Senate Economic References Committee, The structure and distributive effects of the Australian taxation system (2004), p 62.
8 Australian National Audit Office (ANAO), Strategies and Activities to Address the Cash and Hidden Economy (2016).
9 Commissioner of Taxation, Annual Report 2015-16 (2016) p 43.
10 ATO, 'Australian tax gaps 2015-16' (2 November 2016) <www.ato.gov.au>.
11 Her Majesty's Revenue & Customs (HMRC), Measuring tax gaps 2016 edition (2016) <www.gov.uk>.
13 Organisation for Economic Cooperation and Development (OECD), Reducing opportunities for tax non-compliance in the underground economy (2012), p 2.
17 National Taxpayer Advocate (NTA), 2007 Annual Report to Congress Volume 2 (2008) <www.irs.gov>, p 4.
19 Internal Revenue Service, 'National Taxpayer Advocate Delivers Report to Congress' (IR-2008-4, 9 January 2008) < www.irs.gov>.
20 New Zealand Inland Revenue Department, The Hidden Economy (2011) <www.ird.govt.nz>.
21 HMRC, 'Proposals to tackle the hidden economy' (26 August 2006) <www.gov.uk>.
22 HMRC, New campaign against tax evasion (November 2012) <www.gov.uk>.
23 HMRC, 'Tackling the hidden economy: extension of data-gathering powers to money service businesses' (26 August 2016) <www.gov.uk>.
24 HMRC, 'Tackling the hidden economy: Sanctions' (26 August 2016) <www.gov.uk>.
25 HMRC, 'Tackling the hidden economy: Conditionality' (26 August 2016) <www.gov.uk>.
27 Peter Costello MP, Tax Reform: Not a new tax, a new tax system (August 1998) <archive.treasury.gov.au>.
30 IGT, Review into the Australian Taxation Office's use of benchmarking to target the cash economy (2012) p 7.
31 ATO, 'Working with industry' (11 January 2017) <www.ato.gov.au>.
32 Above n 8, p 7.
35 Above n 8, p 16.
38 Kelly O'Dwyer MP, 'Black Economy Taskforce' (Media Release, 14 December 2016) <jkmo.ministers.treasury.gov.au>.
41 ATO, 'Commissioner and Minister Senate estimates briefing' (October 2012) <http://foi.iorder.com.au>.
42 Above n 30, p 67.
43 Above n 30, p 67.
44 IGT, Review into aspects of the Australian Taxation Office's use of compliance risk assessment tools (2014), p 142.
47 Cash Economy Taskforce, Improving tax compliance in the cash economy (April 1998), pp ii and iii.
48 IGT, 'IGT Work Program 2017' (31 January 2017) <www.igt.gov.au>.
50 OECD, Together for Better Outcomes: Engaging and Involving SME Taxpayers and Stakeholders (2013) pp 16-18.
51 OECD, Increasing Taxpayers' Use of Self-Service Channels (OECD Publishing, 2014) p 35.
52 OECD, Study into the Role of Tax Intermediaries (2008) p 14.
53 Productivity Commission, Regulatory Engagement with Small Business (2013) p 141.
54 Above n 9, p 46.
55 IGT, The Australian Taxation Office's services and support for tax practitioners (2015) p 2; see also: ANAO, The Australian Taxation Office's Management of its Relationship with Tax Practitioners (2002) p 12.
56 OECD, Tax Administration 2015 Comparative Information on OECD and other Advanced and Emerging Economies (2015) p 267.
57 Above n 9, p 46.
58 ATO, 'Digital by default' (undated) <lets-talk.ato.gov.au/>.
60 Above n 53, p 164.
61 ATO, Online services: Individuals and sole traders' (9 August 2016) <www.ato.gov.au>; ATO, Online services: Tax agents' (13 May 2016) <www.ato.gov.au>; ATO, Online services: BAS agents' (30 March 2016) <www.ato.gov.au>.
62 ATO, 'Digital by Default – Findings report' (undated), <lets-talk.ato.gov.au >.
66 Above n 53, p 293.
68 Above n 44, p 81.
69 Above n 44, p iii.
70 Productivity Commission, Compliance Costs of Taxation in Australia (1996) <http://www.pc.gov.au>.
71 Chris Evans, Phil Lignier and Binh Tran-Nam, Tax Compliance Costs for the Small and Medium Enterprise Sector: Recent Evidence from Australia (26 September 2013) <https://tarc.exeter.ac.uk>; Chris Evans, Phil Lignier and Binh Tran-Nam, 'The Tax Compliance Costs of Large Corporations: An Empirical Inquiry and Comparative Analysis' Canadian Tax Journal (2016) 64:4, 751-93.
72 OECD, Taxation of SMEs in OECD and G20 Countries, OECD Tax Policy Studies (2015), p 13; Productivity Commission, Regulator Engagement with Small Businesses (2013) pp 72-73.
73 Jacqueline Coolidge, (2012), 'Findings of tax compliance cost surveys in developing countries' (2012) eJournal of Tax Research, 10(2), pp. 250-287.
75 IGT, Above n 55.
76 IGT, Above n 55, p 10.
77 IGT, Above n 55, pp iii-iv.
78 OECD, Rethinking Tax Services: The Changing Role of Tax Service Providers in SME Tax Compliance (2016) p 58.
82 ATO, 'Our services for people with disability' (7 January 2016) <www.ato.gov.au>.
83 NTA, 2016 Annual Report to Congress (2017), p 20.
85 ATO, 'Commissioner of Taxation, Chris Jordan AO on system outages' (Media Statement, 16 December 2016) <www.lets-talk.ato.gov.au>.
86 See for example, IGT, Review into the ATO's Change Program (2010).
87 ATO, 'ATO systems update' (24 January 2017) <lets-talk.ato.gov.au>.
88 IGT, Review into improving the self assessment system (2013) p 63.
89 Australian Public Service Commission, Capability Review Australian Taxation Office (2013) p 9.
90 ATO, ATO IT Strategy Summary (July 2014) pp 3-7.
91 Data may also be received by the ATO through memoranda of understanding with other government agencies, through use of its information gathering powers or under various treaties and double tax agreements with foreign revenue authorities.
92 Above n 56, p 256.
93 Canada Revenue Agency (CRA), 'About Auto-fill my return' (2 February 2017) <www.cra-arc.gc.ca>.
94 Above n 56, p 256.
96 Jason Kerr, 'Tax return simplification: risk key engagement, a return to risk?' eJournal of Tax Research (2012) vol 10, no 2, pp 465-482.
98 OECD, Third Party Reporting Arrangements and Pre-filled Tax Returns: The Danish and Swedish Approaches (2008), p 4.
100 OECD, Using Third Party Information Reports to Assist Taxpayers Meet Their Return Filing Obligations – Country Experiences with the Use of Pre-Populated Personal Tax Returns (2006).
101 ANAO, The Australian Taxation Office's Use of Data Matching and Analytics in Tax Administration (2008) 85.
102 OECD, Tax repayments: Maintaining the Balance Between Refund Service Delivery, Compliance and Integrity (2011) p 9.
103 IGT, Review into the Australian Taxation Office's compliance approach to individual taxpayers – use of data matching (2014).
106 Fraser Institute, Prefilled Personal Income Tax Returns A Comparative Analysis of Australia, Belgium, California, Québec, and Spain (2011) p 13.
107 Above n 103, p 42.
108 Above n 103, p 43.
109 ATO, Smarter Data Program reinventing data and analytics – the ATO experience (Presentation delivered to SAS, May 2015) <www.sas.com>.
110 Above n 96, p 466.
111 Above n 51 (2014).
113 IGT, Above n 55.
120 IGT, Above n 55, p 68-69.
124 Josh Frydenberg MP, 'Cutting red tape for employers through Single Touch Payroll' (Media Release, 28 December 2015) <jaf.ministers.treasury.gov.au>.
125 Budget Savings (Omnibus) Act 2016 sch 23 pt 1 div 3.
126 ATO, 'Simpler reporting with Single Touch Payroll' (1 December 2016) <www.ato.gov.au>.
127 Taxation Administration Act 1953 Sch 1 s 389-20.
128 House of Representatives, Revised Explanatory Memorandum, Budget Savings (Omnibus) Bill 2016, p 265.
129 The Treasury, Regulation Impact Statement: Single Touch Payroll (October 2015) p 39.
131 Above n 128, p 283.
132 The IGT has examined STP as part of his Review into the Australian Taxation Office's employer obligation compliance activities. The report has been transmitted to the Minister but has not yet been publicly released.
133 Accenture Consulting, 'Australian Taxation Office – How the Australian Taxation Office is driving digital communication to Australian Taxpayers' (undated) < www.accenture.com>.
134 ATO, 'Current ATO SMS and email activities' (17 October 2016) <www.ato.gov.au>.
135 OECD, Social Media Use by Governments: A Policy Primer to Discuss Trends, Identify Policy Opportunities and Guide Decision Maker (2014) p 3.
137 ATO, 'Find us on social media' (1 March 2016) < www.ato.gov.au>.
138 ATO, 'Social media' (7 March 2016) <www.ato.gov.au>.
139 Above n 135, p 4.
141 Brett Williamson, 'Tax Office Trawls Facebook, Instagram and other social media to catch out dodgers, cheats' (17 November 2016) <www.abc.net.au>.
142 OECD, Advanced analytics for better tax administration: Putting data to work (2016) pp 21-22.
144 IGT, Above n 55, p 51.
145 ATO, 'ATO launches voice authentication' (8 April 2014) <www.ato.gov.au>.
146 ATO, 'Introducing Alex, our new web assistant' (15 September 2015) <www.ato.gov.au>.
147 NSW Premier and Cabinet, 'Behavioural Insights Community of Practice' (undated) <bi.dpc.nsw.gov.au>.
148 UK Cabinet Office Behavioural Insights Team, 'Who are we' (undated) <www.behaviouralinsights.co.uk>.
149 UK Cabinet Office Behavioural Insights Team, Applying behavioural insights to reduce fraud, error and debt (2012), p 21.
150 NSW Premier and Cabinet, 'Behavioural Insights in NSW 2016' (19 December 2016) <bi.dpc.nsw.gov.au>.
151 Department of the Prime Minister and Cabinet, 'Behavioural Economics' (undated) <www.dpmc.gov.au>.
152 IGT, Debt Collection (2015) p 51.
153 ATO, 'Better communication to improve payment compliance' (7 March 2016) <www.ato.gov.au>.
154 Above n 152, p 133.
156 Above n 98, p 7.
158 Australian Public Service Commission, 'Changing behaviour: A public policy perspective' (14 December 2015) <www.apsc.gov.au>.
159 IGT, Review into the Australia Taxation Office's compliance approach to individual taxpayers – income tax refund integrity program (2013).
160 Above n 103, pp 55-56 .
161 Above n 44, pp 148-149.
162 Above n 152, pp 51, 86, 133.
163 IGT, Review into the Australian Taxation Office's compliance approach to individual taxpayers – superannuation excess contributions tax (2014) p 60.
164 IGT, Review into the Australian Taxation Office's administration of penalties (2014) pp 5-6.
165 Rachel Lilley, Mark Whitehead, Rachel Howell, Rhys Jones and Jessica Pykett, 'Mindfulness Behaviour Change and Engagement in Public Policy – An evaluation' (October 2014) <www.sps.ed.ac.uk> p 4.