The current threshold for which a valid GST tax invoice must be held in order to claim input tax credits is $82.50 GST inclusive. This threshold imposes large administrative costs on businesses. Propose the threshold be increased to $150 GST inclusive.
There is currently little guidance provided to the mining industry on Research and Development (R&D) and its interactions with the tax system. Propose that the ATO provide consistent levels of R&D guidance/advice across all industries in order to provide clarity and certainty.
The ATO should consider reviewing the usefulness and relevancy of its advice and guidance in respect of schemes to provide certain benefits (section 45B of the ITAA 1936) and update it as required.
Need further guidance from the ATO with respect to Employee Share Schemes (ESS) and whether interests in certain common kinds of foreign vehicles (such as a limited liability company) qualify as 'shares' or 'ordinary shares' under the ESS rules, in particular, subsections 83A-10(1) and 83A-45(2) of the ITAA 1997.
For large withholders, the total salary and wages amount recorded at label W1 on a Business Activity Statement (BAS) is not used for the purposes of any calculations within the BAS. However, conducting the calculations required in order to complete this label can be administratively burdensome. Propose that the requirement to complete this label be removed for large withholders.
The inclusion of deferred tax liabilities in the tax cost setting process adds complexity to the consolidations regime and results in a mismatch of tax and commercial outcomes. Propose deferred tax liabilities be excluded from the entry and exit tax cost setting calculations.
The rules governing the Superannuation Guarantee Charge (SGC) regime are complex and onerous to the extent that many SME's ignore SGC for late super remissions. These rules should be substantially simplified in order to provide clarity and improved compliance.
The Interests on Overpayments (IOP) regime needs to be overhauled. The current system is difficult to understand and administratively complex.
There is considerably uncertainty in the automotive industry as to which dealer incentives are subject to GST and which are not. Amend GST law to provide clarity by ensuring all dealer incentives are subject to GST.
Each State has its own system with inconsistent record keeping requirements in relation to Royalties. To ease compliance burdens and reduce uncertainty, consider developing a 'pro-forma' system that each of the States could adopt.