2025 ATO Supplementary Annual GST Return Guide for Public & Multinational Companies

Public and multinational companies that receive a GST assurance rating through a Top 100 or Top 1,000 assurance review program must submit a supplementary annual GST return to the Australian Taxation Office (ATO) via email. On May 7, the ATO published instructions on completing each section of the 2025 return form to help in-scope companies successfully and accurately complete the supplementary annual GST return.

Scope of Instructions

The instructions are divided into several sections, covering each of the sections included in the supplementary annual GST return form. Therefore, the instructions cover basic information, such as details of the entity submitting the return. 

Additionally, the ATO recommended that companies subject to this obligation should include governance recommendations or suggested enhancements from their earlier review and any recommendations concerning specific risks or issues. This may consist of any action those companies took to address each of the ATO's recommendations or to resolve any red flags pointed out by the ATO.

Furthermore, the instructions answer key questions regarding completing the GST governance, reconciling audited financial statements and business activity statements (BAS), material uncertain GST positions, and material GST reporting errors or credits claimed in a later BAS sections of the supplementary return.

The instructions provide essential information on administrative penalties imposed on those who fail to file a return on time or file a false or misleading return. Finally, the instructions also include an example of a correctly completed supplementary GST return, which may be helpful for those facing filing obligations for the first time.

Conclusion

Businesses that received a notification from the ATO that they must complete and file the supplementary return should carefully examine the provided instructions and ensure they file the required GST return on time and correctly. Since this obligation is imposed only on the so-called significant global entity (SGE), penalties for such entities are higher than for small, medium, or large entities.

Source: Australian Taxation Office