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ICB Definitive Guide Single Touch Payroll

Edition 1 January 2017

All updates available at: www.icb.org.au/STP

ICB Definitive Guide to Single Touch Payroll

Edition 1 Published January 2017

This is an ICB publication. It is based on information known from part of the ATO consultations, information, public briefings and the design process. While based on law and Ministers released information, it is not necessarily the final position nor the reflective of what may be the final ATO implementation and requirements. This edition is the best information available at the time of publication. Updates will be available at www.icb.org.au/STP

Acknowledgement of ATO The Single Touch Payroll project has the involvement of various levels of Government. The respective Assistant Treasurers, working with Treasury and the implementation agency of the Australian Taxation Office. The ATO commenced consultations on this project in 2013 and should be commended for their intense engagement with key stakeholders. Business and Bookkeepers through the community of members of ICB (amongst others) have ensured that Government consider the impact of this regime on employers and their advisors.

Limitation of Liability

The material contained within this manual is designed to provide information for bookkeepers and business.

We note that different circumstances might apply from Bookkeeper to Bookkeeper and situation to situation.

Before you rely on this information for any important matters you should make your own enquiries and validation to ascertain if it is appropriate and correct to your circumstances.

All rights reserved.

No part of this manual maybe reproduced or copied in any form or by any means (graphic, electronic or mechanical, including photocopying or by information retrieval systems) without permission in writing from Institute of Certified Bookkeepers.

ICB may take legal action against a person who infringes on their copyright through unauthorised copying.

Copyright © 2017 Institute of Certified Bookkeepers Pty Ltd

_______________________________________________________________________________________Single Touch Payroll (January 2017) ©TheInstituteofCertifiedBookkeepers Page3

Business Information Sheet .......................................................................................................... 5 Implementation Timeline ............................................................................................................... 6 Introduction ..................................................................................................................................... 7 A Simple View ................................................................................................................................. 8 ICB Policy Position on STP ........................................................................................................... 9 Important Concepts ...................................................................................................................... 10 Why STP? ..................................................................................................................................... 12 Your Approach .............................................................................................................................. 14 Templates .................................................................................................................................. 16 A Guide for Business ................................................................................................................... 17 Payroll Process and Development with an STP Program...............................................................18

The Detail ...................................................................................................................................... 22 Legislation ................................................................................................................................. 22 Technical – What the Software must do for you ........................................................................ 23 Technical – What the Government Must Deliver ....................................................................... 24 STP Processes .......................................................................................................................... 25

a.) Onboarding/Commencement of a New Employee .......................................................... 25 b.) PayEvent ......................................................................................................................... 25 c.) Annual Reporting ............................................................................................................. 31 d.) Superannuation Payment Reporting ............................................................................... 32

When to Start with STP ................................................................................................................ 33 Reconciliation and Corrections .................................................................................................. 34 ICB Submission Reconciliation & Correction ............................................................................ 35 Compliance Action by the ATO ................................................................................................... 41 ICB Submission – ATO Compliance Actions ............................................................................. 42 What if You Cannot Report to STP? ........................................................................................... 43 Software Companies .................................................................................................................... 43 Authorisation & Declaration ........................................................................................................ 50 Bookkeeping Process Impacts ................................................................................................... 51 Project Status ............................................................................................................................... 22 ICB Confidence Level................................................................................................................... 53 STP - Frequently Asked Questions............................................................................................. 54

Table of Contents


Glossary and Additional References .......................................................................................... 60 Appendix ....................................................................................................................................... 61 ICB Resource: Commencing a Process Payroll ....................................................................... 61 ICB Resource: SuperStream .................................................................................................... 61 ICB Resource: PAYGW Obligations of an Employer ............................................................... 63 New Employee Checklist ........................................................................................................... 65 The Cash Flow Debate .............................................................................................................. 67 History of the Journey ............................................................................................................... 71 ATO Consultation Framework ..................................................................................................... 78

Further Resources

ICB • http://www.icb.org.au/Single-Touch-Payroll

ATO • https://www.ato.gov.au/About-ATO/About-us/In-detail/Strategic-direction/Simpler-reporting-

with-Single-Touch-Payroll/• http://lets-talk.ato.gov.au/

Legislation • https://www.legislation.gov.au/Details/C2016A00055


Your Payroll seen by the ATO ….. All Year The Single Touch Payroll (STP) legislation has received Royal Assent. It is law and is going to happen!

Who? All “substantial” employers, (20 or more employees by headcount), must participate.

§ The count happens as of 30 April each year, commencing 2018.§ You must then enter STP as of 1 July 2018 or the July following achieving 20.

Anyone can elect to enter STP earlier. Smaller employers may volunteer to use STP: The ATO are undertaking further research before Government consider making it mandatory.

What? You submit payroll and superannuation data to the ATO each “PayEvent”. A PayEvent is each time you pay someone and should be generating a pay slip. Some of the data on the pay slip is now sent to the ATO:

§ The year-to-date totals of gross wages and gross tax for each employee being paid.§ The amount of Superannuation Guarantee (SG) that has been accrued.

Superannuation payment information is also sent at the time of paying your Superannuation Guarantee Contribution, (SGC).

How? Your payroll software should do it all for you. If you do not have accounting software or internet, the ATO are considering other reporting mechanisms.

When? The ATO is required to be ready to receive STP information as of 1 July 2017. Substantial employers must provide STP information from 1 July 2018. Other employers are not required to provide STP information at this time. Any employer can enter STP as soon as they are able.

Why? § The ATO will gain greater visibility of all employers, enabling earlier activity to ensure the

employer is paying their PAYGW and their SGC.§ The employer will no longer be required to provide payment summaries to their employees.

The ATO will provide them.§ The ATO will prefill tax returns with the payroll information.§ The ATO will make the payroll information available to employees all year through myGov.

Future The ATO will streamline the process for a new employee by automating the Tax File Number Declaration and SuperChoice form into payroll software and myGov.

Business Information Sheet Single Touch Payroll

_______________________________________________________________________________________Single Touch Payroll (January 2017) ©TheInstituteofCertifiedBookkeepersPage6

Important The employer’s payroll records are always the “source of truth”. Therefore, any amendments to past pays, or any fixes required are updated in the employer’s systems and records. At the next PayEvent the ATO will receive the updated YTD information. There is no need to go back and amend past PayEvents. The employer will still have to “finalise” a payroll year by indicating to the ATO that the information they are now being sent is the final version and can be used for tax returns. Implementation Timeline Dates to Watch Out For

Consider your payroll systems and streamlining process to meet the STP Reporting requirements Now

Legislative Instruments prescribing the form of Data required by STP (14 parliament sitting days required following the tabling of the LI) TBA

ATO to be able to receive STP submissions 01 July 2017

All employers can commence STP if they wish to as from ATO readiness

Employers to check headcount as of (if 20 or more then must commence STP as from next 1 July)

01 April 2018

Commence implementation of STP compliant software 02 April 2018

STP commences for substantial employers - PayEvent reporting commences at this date.

01 July 2018

Small Employer research and recommendation to be considered 2018


This guide is to provide bookkeepers and businesses with the ability to understand:

§ What Single Touch Payroll (STP) is. § What an employer must do and when. § How to comply.

The Institute of Certified Bookkeepers is a professional association of Bookkeepers helping Bookkeepers helping Business. Single Touch Payroll is an initiative of Government affecting every employer and arguably every employee. This guide will take you into an understanding and then practical implementation steps based on what is being implemented in the foreseeable future. This guide will be updated from time to time and you can stay right up to date with any changes that affect you through connecting with the ICB.

§ Members: www.icb.org.au/Resources/Payroll/Single-Touch-Payroll § Bookkeepers: www.icb.org.au/membership § Businesses: www.icb.org.au/Who-Are-You/Business-Owners/Benefits

Introduction


Every employer is endeavouring to meet all their employer obligations under Fair Work and ATO, (or should be). Every employer has a payroll system of some sort that is regularly producing payslips and end of year payment summaries and calculating Superannuation Guarantee and PAYGW calculations and arranging payment. None of the above changes really. STP has come along and what it does (or should do) is provide visibility to the regulator and also the employee, of what the employer is doing. The data (payroll info) that the employer creates anyway will now be sent to the ATO periodically. Note that the employer’s records remain the source of truth. If the ATO has a problem or finds an error, the employer can fix it next time. There is no need to ever reconcile to what has been submitted to the ATO, simply verify the employer’s records and submit the current copy of the source of truth, (the information in the employers system), to the ATO. The ATO information is then updated. Superannuation Guarantee (SG) payments are already submitted to the SuperStream system and the ATO will now get a copy of the payment information. STP means the accruing of an SG obligation will be seen by the ATO in the PayEvent information and the periodical payments will offset that obligation. The ATO has an obligation to follow up with action on the information provided or not provided. The ATO should, with STP, be able to catch the crooks earlier. The ATO should, with STP, be able to leave the compliant guys alone. As to benefits for employers, we are yet to be convinced. As to benefits for employees, we are yet to be convinced. Unless it is catching the crooks.

A Simple View


ICB are supporters of the concept of a Single Touch Payroll. We support the discussion and development of Single Touch Payroll and ICB seeks to continue our engagement with and to assist in the implementation of a successful and appropriate STP program. We completely support the development of a software integration with some government services that assist employers to manage their payroll more efficiently. We are concerned that government has not given sufficient credit or time to recognise the current well developed state of payroll process and software as it already exists. The further development of software to assist employers to be more efficient, including their interactions with Government, should be encouraged and we believe can be implemented without significant negative consequences. It should be noted that the ATO STP proposal does not remove any complexity for an employer. The bookkeeping, record keeping, HR and payroll complexities remain in place for all employers. The STP discussions have not adequately recognised the ongoing obligations that Fair Work places on an employer. We are surprised that Fair Work has not been involved in the development of the proposal. We support an enhancement to government systems to allow more effective and efficient “onboarding” (commencement) of a new employee by an employer. We also support a better process replacing the current TFN Declaration and the SuperChoice systems and forms. This should be facilitated through Government enabling Business Management Payroll software as a priority. The involvement in a new myGov information process should be secondary. We support the increased visibility that will be provided to government, through STP. The ATO will have more timely information and therefore an ability to monitor and react to the behaviour of employers. This requires an appropriate compliance approach by government to follow up employers who are not meeting their obligations. We support the approach that the current SGC and PAYG Withholding payment cycles should not be altered. Payment should NOT be brought forward for any employers. We do consider that it is appropriate to consider earlier payment requirements for employers who have a proven history of non-compliance. We propose and support significant transitional considerations. We support and require the approach that the employer’s records are the source of truth and the information provided to the ATO can be updated by the employer. It cannot be a requirement to reconcile back to whatever information the ATO has. It remains a requirement to have correct records with the employer.

ICB Policy Position on STP

ICB Policy Position on STP


1. It is happening. It is Law and commences for some on 1 July 2018.

2. “PayEvent” is the trigger for a requirement to report data to the ATO. It is the event of

paying an employee. The employer has a requirement to pay the employee, a requirement to provide a payslip and now has a requirement to advise the ATO of pay information.

3. “Year to Date” values for each employee being paid is required.

4. “Source of Truth” is a design principle behind STP that at all time it is the employer’s current records that are considered the “source of truth”.

This has very deliberate consequences, (all positive), for the employer. If the employer needs to amend a pay event, within the current financial year, they do so in their own system and, (subject to thresholds), will NOT need to amend the previous information sent to the ATO. No amendments to PayEvents. The next PayEvent reporting will included the updated “year to date” information for that employee and therefore will include any amended values.

5. “Reconciliation” with the ATO STP information is NOT required. Because you are able to

update the ATO information at the next PayEvent with the new Year To Date values, it is the employer’s own system, (the “source of truth”), that must be verified and the employer’s records would be the ones subject to any further review. The previous STP submissions to the ATO are not, prima facie, relevant and do not need to be amended. Previous BAS or large employer payments may need to be amended.

6. “Prefill of the BAS” by the ATO with the values for W1 (gross wages) and W2 (tax withheld) will be provided on each BAS but can be overridden without consequence. The ATO has the information based on what has been submitted. The employer’s records are the ultimate source of truth so may be different, i.e., including amendments.

7. Superannuation payments are also required to be reported as part of STP. Employers are

already reporting payments into the SuperStream system, therefore the design is that STP will receive and process based on the same message.

8. Cash flow does not change under STP. You may pay early if you wish but STP does NOT

require you to. You may pay according to existing schedules. For the PAYGW tax: Large withholders (>$1m PAYGW per year) continue to pay weekly; Medium withholders ($1m < $25,000 PAYGW per year) pay monthly; and Small withholders pay quarterly. For your super guarantee payments, the SGC law remains at quarterly, other workplace arrangements may require more frequent payments.

9. “Finalisation” replaces the previous submission of EMPDUPE files, (copies of payment

summaries), to the ATO. By sending a “Finalisation” STP submission, you will be telling the ATO that the data they now have, (as part of that finalisation submission), is to be considered final and can be entered in Income Tax Returns. “Finalisation” must happen by the 14th July.

Important Concepts


10. “RESC” and “RFBA” reporting obligations continue and would be provided to thegovernment as part of the “Finalisation” process.

11. “Amended Finalisation” allows you to resubmit “Finalisation” data for an employee or allemployees, if an amendment is required after a “Finalisation event”.

12. The ATO will have immediate information and therefore will implement a more rapid followup strategy.

a. The ATO will be using “soft touch” enquiry if they see an issue with the STP databeing provided.

b. They will use a stronger and quicker compliance strategy for non-compliantemployers.

13. No increase in work load. It is a design principle that STP is to leverage off the naturalbusiness systems of a compliant effective employer. Accordingly, if the employer isperforming payroll correctly and complying before the introduction of STP, then STP shouldnot increase or add any additional work.

14. Nothing can stop the employer from paying the employee as required. Nothing in the STPreporting system can prohibit or restrict or in any way hinder an employer’s natural businesssystem of being able to pay the employee as required by other Law. If the ATO computer isunable to accept the information or the internet is not working the employer must still beable to do payroll and the next payroll.


What is the reason behind STP? What is STP aiming to achieve? The ICB has recommended concepts such as

“supporting employers using best practice and enhanced and easier compliance for employers.” and “The ATO are seeking to facilitate enhanced but also easier compliance reporting and possibly payment systems for all employers. The proposed “Single Touch Payroll” system would change the way an employer interacts with the ATO in relation to SGC and PAYGW obligations. STP includes enhanced reporting of employee payment activity enabling earlier detection and action to employers who fail to meet their obligations”

We remain very concerned that the basis behind the ATO STP is that it will help resolve PAYGW liability (debt) issues and also SGC issues. In our opinion this view, based on an enhanced reporting obligation alone, is unfounded. The ATO must implement a stronger compliance program behind those taxpayers who do not comply with current obligations rather than increasing the obligations on all. The first consultation/discussion paper by the ATO presented the following:

“Currently, the ATO does not receive reporting information to identify that employers have paid the correct amount of employee super by the due date. Instances where businesses have decided not to do the right thing, and not pay employee super payments, may often go undetected for some time where the employee does not complain. These businesses create an unfair commercial advantage for themselves at the expense of other businesses that do the right thing. This is especially unfair on employees where recovery of unpaid super amounts is delayed or, in extreme cases, no amounts are recovered due to the insolvency of the business. “

The Law (Explanatory Memorandum) explains as follows: This Schedule contains a suite of legislative amendments to create a new modern reporting regime for providing payroll and superannuation information to the ATO.

To complement this reporting regime, the Schedule also contains amendments allowing the ATO to enhance their digital service offering for employers in relation to processes associated with bringing new employees onto their payroll. This includes enhanced TFN validation services, which will provide employers with confidence that details they hold about their employees matches the information held by the ATO for that employee.

Collectively, these amendments are designed to reduce the compliance costs for employers of meeting their PAYG withholding and superannuation obligations, whilst also improving the ATO’s ability to monitor employer compliance with their SG obligations. “

GreaterVisibility STP will provide government with greater visibility of:

a) what employers (who report) are doing b) which employers are not reporting

Why STP?


Government will also now see the behaviour of employers around accruing and then paying SGC and PAYGW. STP will bring forward the ability of government to monitor non-compliant or struggling employers and to provide appropriate assistance or “encouragement”. (ICB support the increased more frequent visibility on the basis that the ATO will appropriately and rapidly follow up what they are seeing). The Government provide the following outcomes: Outcomes that ICB agree are possible:

§ Better “commencement of new employee” process (streamlined TFN Dec and SuperChoice process)

§ Greater visibility to Government of employers who are NOT meeting their obligations enabling quicker and appropriate compliance action

o Super gets paid o PAYGW gets paid

§ Encourages development of better digital interactions in the entire payroll function § ATO will monitor and advise employees about their Superannuation Contribution caps

Outcome that ICB are yet to see as possible or even likely:

§ Less red tape § Less regulatory burden

WhatElseWillChange?

1. The end of year process will only be changed as far as the method of submission to the ATO. In recent years we had to send our end of year payment summary to the ATO electronically, mostly an EMPDUPE file lodged through software or ATO portals.

In STP you will send aa “finalisation message” that includes the final data. In effect the EMPDUPE file into a different computer at the ATO. Previously EMPDUPE files could be submitted to the ATO by the 14th August, after providing payment summaries to the employees by the 14th July. The finalisation message must be sent by the 14th July. “Finalisation” can be amended.

2. Payment Summaries will not need to be provided in the ATO format to employees by employers; in fact, allegedly the employer doesn’t have to provide anything to employees. We do not believe this will be effective for a number of years.

In STP the ATO will provide the Payment Summary to the employee, based on the “Finalisation data”

3. Allowing early payment of PAYGW to the ATO and SGC if an employer wishes to manage their cash flow in this way. We note this is NOT a requirement.

4. The ATO will now prefill each BAS for (appropriate) employers with the W1 (gross wages)

and the W2 (tax withheld) amounts based on the information provided in the STP transmissions. These amounts can be overwritten. (ICB remain dubious of the ability of the ATO to provide this accurately and to include end of period payroll data as well as we don’t perceive any benefit).


A guide for ICB Members

Be the first to be ready STP will provide another reason for everybody who knows your business/es to claim that they are the ones to help solve the STP implementation, therefore:

§ Understand today’s best practice payroll systems

§ Understand what STP is o Read this Definitive Guide o Watch the recorded ICB Single Touch Payroll Webinar o Undertake the ICB Single Touch Payroll accreditation

You should be the first. Bookkeepers typically are the ones who know the business operations in the best detail and therefore can interpret the new system and apply it to each business appropriately.

§ Provide each business with the ICB Business Information Sheet on STP § Review how each business is currently performing its payroll § Understand how each software you work with is going to implement STP § Schedule a briefing and recommendation session with each business § Schedule when STP must be implemented for each business

What’s in it for Bookkeepers

§ NOCHANGEtoreconcilingpayrolleachquarterbeforeBAS.

§ Allemployerswillrequiresometypeofelectronicpayroll/accountingsoftware– increasedbusinessforbookkeepers

§ ATOarelookingintoanothertypeofserviceifEmployerisnotcomputerised.Ie.AustraliaPostorAgentslodgingonthebehalf

§ NOCHANGEtoEOYreconciliationbesidesATOemailingemployeespaymentsummaries

– ‘FinalIndicator’issenttoATOaspartofEOYprocess

Your Approach


StayuptoDate STP will continue to develop. We have already heard about STP stage 3 (and we haven’t even implemented stage 1 yet). The Government will progressively implement STP and each step of implementation may change how payroll works for employers.

§ Stay connected with ICB § Receive the ICB newsletter

Be Ready

§ When your software has an STP enabled payroll be ready to implement it. Despite what you may hear….

Single Touch Payroll does NOT § Remove any normal reporting obligation upon employers § Automate any part of the employer’s obligations § Simplify or streamline payroll An employer must still § Obtain a SuperChoice form (or use a default fund) § Obtain TFN Declaration information § Comply with Fair Work requirements § Issue payslips § Pay employees, pay super, comply with SuperStream, pay the PAYGW

Good payroll software will help achieve all of the above outcomes and also meet your STP reporting obligations. STP should motivate more employers to use good payroll software. Bookkeepers should be the ones recommending what software the business should be adopting. Bookkeepers’ImplementationofSTP If the Government get the concept, design and implementation from their side correct, this will enable the software companies to deliver a better customer experience in everything required to be performed to comply with payroll obligations. As bookkeepers, our role is to understand what the law is requiring, how the Government have then implemented the system, utilise software that embraces STP in a better process and then help each of our businesses become more effective and more efficient as part of embracing the new system. Bookkeepers therefore should:

1. Understand what data is now being sent to the government each PayEvent. 2. Understand what STP requires in terms of commencement of an employee,the finalisation

process at the end of the year and seek to use the software that embraces this system. 3. Understand how the software you use has implemented STP. 4. Understand and implement new procedures in the software for commencement of an

employee. 5. Understand and perform the STP end of year “Finalisation” process delivered by the

software to embrace STP 6. Provide each business with an understanding that you are an expert in STP and STP

enabled software and that you will be using the new enhanced system for their business.


Templates At the time of publication, the technical specifications and processes have not been completed. The following templates are envisaged and indicative of best practice requirements based on our understanding of how STP will be implemented. Updates available on ICB website: www.icb.org.au/singletouchpayroll

1. Using myGov a. Explanation information to the employer b. Employer authorising the establishment and use of the myGov connection c. Explanation information to the employee d. Employee authorising the employer to receive the information

2. Using BMS (Business Management Software) a. Employer providing authorisation to the bookkeeper b. Explanation information to the employee c. Authorisation from employee to include

i. Authority to send payslips and other information electronically ii. Acknowledgement that Payment Summaries will be provided by myGov

3. Employee induction pack


Be informed and not misled STP will provide another reason for everybody who knows your business/es to claim that they are the ones to help you solve your STP implementation.

§ Engage an STP accredited ICB member to assist you. § Understand what STP is by reading this Definitive Guide

Bookkeepers typically are the ones who know your business operations in the best relevant detail and therefore can interpret the new system and apply it for you appropriately.

§ Understand the ICB Business Information Sheet – now § Review how you currently perform payroll processing § Understand how each software you work with is going to implement STP § Schedule when STP must be implemented

Stay up to date STP will continue to develop. We have already heard about STP stage 3 (and we haven’t even implemented stage 1 yet). The government will progressively implement STP and each step of implementation may change how payroll works for employers.

§ Stay connected with ICB § Receive the ICB newsletter

Be ready

§ When your software has an STP enabled payroll be ready to implement it Despite what you may hear…. Single Touch Payroll does NOT

§ Remove any normal reporting obligation upon employers § Automate any part of the employer’s obligations § Simplify or streamline payroll

An employer must still

§ Obtain a SuperChoice form (or use a default fund) § Obtain TFN Declaration information § Comply with Fair Work requirements § Issue payslips § Pay employees, pay super, comply with SuperStream, pay the PAYGW

Good payroll software will help achieve all of the above outcomes and also meet your STP reporting obligations. STP should motivate more employers to use good payroll software. Bookkeepers should be the ones recommending what software the business should be adopting.

A Guide for Business


The ICB explanation of the concept “Your payroll seen by the ATO …. All year” An initiative of Government as part of the enabling Digital by Default policy for the improvement of Business process in Australia. In the below we outline a complete payroll process required by an employer from the requirement to register through to cessation of an employer. We outline this payroll process within the context of an STP development, which may or may not include elements of the ATO proposal. Included is comment as to the warranted and envisaged, (if not under construction), enhancements to commercially available payroll software that we are aware of and should be delivered with or without the ATO STP proposal. Please note that this explanation is of current processes and ideal processes which may or may not be what is proposed by the ATO and may or may not be part of STP. We will update this report on our website. Status Dashboard achieving an ideal “Single Touch Payroll” world.

Positive - Not perfect Underway - Not there yet

Significant Work Required Required - Not yet observed

Out of Scope Included in STP Developments

1. Registration (ABN, TFN, PAYGW)

§ Recent changes to the ABR and the registration process to automate and simplify registration towards a “Single Touch” registration should be acknowledged and continued.

2. Registration (Superfunds, SuperStream, Super Clearing House)

§ Current implementation of SuperStream by the software (and their links with clearing houses and payment gateways) is heading towards an employer being able to establish SuperStream compliance within the software in a streamlined approach.

3. Acquisition of Payroll Knowledge (Internal or Consultant)

§ Payroll is complex: Fair Work and tax and super. Employers must seek professional help to ensure they understand the law, understand their obligations and implement system to comply, as the consequences are dire.

Payroll Process and Development with an STP Program


§ Alternatively, if the system was to provide certainty / safe harbour to employers basedon engaged actions to establish correctly then the cost and burden of acquisition ofappropriate knowledge may be reduced.

4. Establishment of Software (Acquisition, Training, Setup)(Alternative non-software system set up)

§ Software establishment and training is established (varies brand to brand)

§ Employers should be supported in their acquisition of software and then in ensuringcorrect establishment of the system in the software.

§ Payroll in Australia does not apply to each employer the same way hencecustomisation is always required. It is false to expect software will ensure compliance.Effective communication of the requirement to seek expert assistance should bepromoted.

5. Engage Employees

a. Interview and offer process b.

b. Employment contract a.

§ Although we rank these as out of scope, increasingly HR software that assists theseprocesses is coming to the market. A truly “Single Touch” payroll process would integratethis process with the engagement of an employee

c. Employee details to be acquired (“Commencement”) a.

i. Award details to be determined and applied ii.

iii. TFN Dec information iv.

v. Super Information vi.

d. Establish employees in the Payroll systema.

§ Different brands are at different stages of what we would refer to as best practice andefficient business process. Further development is required. STP should drive a digitalinterchange of information that further facilitates this process.

6. Receive Pay Run Processing Instructions

§ Different brands are at different stages of applying best practice and efficient businessprocess to various different business circumstances.

§ In a full STP world automation of the information and authorisation processes will bemore “digitally” facilitated. Similar to current developments in the Purchase Invoicerecognition and processing procedures, we believe pay run information should follow asimilar process.

7. Process Pay Runa. Calculate gross amounts to be paidb. Apply taxes etc. c.

c. Verification and authorisation to make payments d.


d. Payslips to be provided to the employee e.

e. Payment instructions for the employee’s net pay, (preferably through payment gateway in the software), and make payment

f.

§ The payment instructions through a gateway functionality exists in different software through a variety of different methods. In a true STP world we look for “a”, “b” & “c” to be one set of procedures that generate a set of reports provided to the “authorised person” in the business to then authorise the processing of the payroll.

§ Following authorisation we look for STP button to facilitate “d” & “e”

§ Different brands are at different stages

§ Already payroll software typically then has a process of accumulating the PAYGW and also calculating the SGC obligations for reporting at any time but definitely for inclusion in the Monthly or Quarterly Activity Statement process. Software has typically already removed the “double handling”

8. Monthly or Quarterly Activity Statement a. Review process (varies on extent but tends to be in conjunction with SGC verification)

g.

b. Declare accumulated gross pay h.

c. Declare accumulated PAYGW i.

d. Verification and authorisation to lodge complete Activity Statement j.

§ The preparation of the Activity Statement exists in different software through a variety of different methods. In a true STP world we look for “a”, “b” & “c” to be a set of procedures that enable review and then generation of a set of reports provided to the “authorised person” in the business to then authorise the lodgement of the Activity Statement.

§ Different brands are at different stages.

e. Lodge Activity Statement k.

§ The SBR enabled lodgement of Activity Statements from within the business’ own software as a ST concept appears to be nearby but is not implemented across the board and we are unaware of a truly integrated STP type activity statement lodgement

§ Some practice management software exists to receive transmissions from “payroll” software to then facilitate the lodgement

§ Noting that many Activity Statements contain other compliance obligations outside of Payroll

f. Payment as part of Activity Statement debt l.

§ A STP concept would be that as soon as the Activity Statement can be lodged that lodgement is facilitated and then at the same time the ST concept would have the software scheduling the payment of the Activity Statement debt on the day due for payment. Therefore, no further engagement with the process as it has already been calculated, reviewed, verified, authorised, lodged and it is now scheduled for payment.


9. Quarterly SGC Obligations

a. Review process (tends to be scrutinised to ensure obligations are known) m.

b. Utilise software SuperStream capabilities to n.

i. Send required messaging ii. Send payment to Clearing house with instructions

10. Pre-End of Year

a. May or June SGC review to enable employer to make tax deductible contributions o.

§ Similar process to item 9. Implemented differently by different brands

11. End of Year

a. Total reconciliation and payroll review p.

b. Preparation of Payment Summaries for employees q.

i. RESC amounts to be determined

ii. RFB amounts to be determined

§ Different processes in different software – continual improvement required

§ In STP this will be preparation for “Finalisation” of data

c. Lodgement of Payment Summaries with the ATO r.

§ Similar comment as for activity statements noting that there are distinct differences between brands “the SBR enabled lodgement …. from within the businesses own software as a ST concept appears to be nearby but is not implemented across the board”

§ In STP this will be replaced by the “Finalisation” process. Same outcome but different submission. d. This tends to be the time to facilitate any corrections to SG as the payroll has been more intensely reviewed

s.

e. This tends to be the time to reconcile PAYGW amounts to final year’s payroll figures enabling final Activity Statement adjustment

t.

12. Cessation of Employment

a. Termination pay (often subject to later correction due to incorrect application of tax). u.

b. Notice of separation v.


Legislation https://www.legislation.gov.au/Details/C2016A00055

The Budget Savings (Omnibus) Bill 2016 – Single Touch Payroll received Royal Assent on Friday 16 September 2016.

ATO Guidance This information is to provide the explanation of how the ATO will be implementing STP. It will provide its application of the law and its administration of how STP will affect each employer and the ATO. Topics will include:

§ Compliance program § Exemptions § Thresholds

https://www.ato.gov.au/About-ATO/About-us/In-detail/Strategic-direction/Simpler-reporting-with-Single-Touch-Payroll/ Who needs to report Explanatory Memorandum explains:

Subject to specific exemptions, entities with 20 or more employees (substantial employers) on 1 April 2018 will be required to report under STP from 1 July 2018. Entities that become substantial employers on 1 April in a subsequent year will be required to report under STP from 1 July of that calendar year. [Schedule 23, item 1, subsections 389-5(6) and 389-5(1) and sub item 22(1)]

For the purposes of determining whether an entity is a substantial employer, the number of employees is calculated using a headcount rather than a full-time equivalency. The term ‘employee’ has its ordinary meaning which means that contractors will not be included in the relevant headcount. [Schedule 23, item 1, subsection 389-5(6)]

If you have 20 or more employees as of 1 April, then you must commence STP from the next 1 July. Wholly owned groups are aggregated for the purpose of this headcount. Exemptions may be granted where the 1 April headcount results in an unfair impact on an employer.

The Detail


Technical – What the Software Must do for You

Every pay run, the software must create a PayEvent submission to be sent to the ATO (using ebMS3.0/AS4 (digital message exchange technology), either directly from payroll software or via an intermediary through a gateway, (Business Transaction Network), to the ATO.

The PayEvent submission will be the YTD values of any employee paid in that PayEvent. An employer may have many PayEvents per day or only one per a normal pay cycle (e.g. fortnight). The concept allows out of cycle payments.

The PayEvent submission will also include the total amount of gross wage for that PayEvent only and the amount of PAYGW for that PayEvent only for the employer. This is to allow the prefill of the Activity Statement W1 and W2 amounts.

Every payment of Super, the Payment Contribution message will also be sent to the ATO (currently sent to SuperStream)

At the end of the year, provide a method of including RESC and RFB amounts and then submitting the “Finalisation” set of data for all employees (replacing the EMPDUPE process) to the ATO. They must provide a process for amending the “Finalisation” message.

The software must facilitate an easy method of enabling corrections to payroll that is then reported in alignment with the ATO corrections framework, yet to be determined.

Registering for STP For the “Retail” onboarding process (refer below) the employer would have to register to receive the information which will have to include where myGov notifications are to be sent for the employer and also establish the authorised secure connection between their software and Government to receive the information.

For the “Wholesale” onboarding process (also below) and for the submission of PayEvent and “Finalisation” messages, the employer’s software will also have to be authorised to interact with Government. The existing cloud authentication and authorisation processes, which require software to use a device AUSkey (of the software company) and the software provides a Unique Software ID between the software company and each Business Management System (the businesses software), will facilitate this link.

Your software must have a Unique Software ID that identifies each payroll software system that you use to submit STP information. Some employers have different pay locations running different payroll software but for the same employer, i.e., the same ABN. The two or more different payroll systems will use the same ABN but have different Unique Software IDs which allows the ATO to recognise and accumulate the different systems submissions. If an employee works for multiple locations and is paid by different payroll systems, then that employee will have two different sets of YTD numbers provided through STP to their myGov profile and the ATO will provide two or more different payment summaries being one for each pay location (Unique Software ID).

Software should also facilitate appropriate authorisation processes. These same processes should be in place for management to authorise the payment of staff, following the calculation of the payroll. This authorisation process will now verify that the same data should be submitted to the ATO.


Future § The concept of a having a “payroll finalised” button is consistent with the next advancement

of software. A button that: o Finalises the calculation of the payroll o Finalises the calculation and recognition of the SGC amounts o Finalises the calculation and recognition of PAYGW amount o Obtains the “authorised person’s” sign off to complete and process the payroll o Makes payment to all employees o Sends pay slips to all employees o Schedules the payment of the PAYGW amount for the (future) date required

- The reporting and the payment can be scheduled for different times o Schedules the payment of the SG amounts and sending of the data through the

selected clearing and messaging house for the (future) date required - The reporting and the payment can be scheduled for different times

Technical – What the Government Must Deliver In order for STP to be successfully implemented there is a significant technology and process implementation required by Government. These include:

§ The ATO computer able to receive STP submissions all day everyday o Alternatively, a queuing system for receiving information

§ myGov being able to provide Payment Summaries § ATO providing Payment Summaries when the employee doesn’t have myGov § myGov being able to provide the onboarding interface for employees § myGov being able to interact with employers with the onboarding information § myGov providing a notification system for employees and employers § ATO providing a new process for the BAS, especially if they are prefilling W1 and W2 § ATO process of the data received § A different ATO approach to compliance activities


STP Processes A: Onboarding / Commencement of a new employee Currently an employer undertakes a number of induction and information gathering steps for a new employee:

1. Providing Information about the employer 2. Obtaining Information about the employee, (required for payroll purposes including bank

account details, address etc.) 3. TFN Declaration provided for completion 4. SuperChoice form provided for completion 5. National Employment Standards notice 6. Fair Work requirements

It is envisaged that eventually under STP items #3 TFN Declaration and #4 SuperChoice are replaced by providing in an employee induction pack explanation to the employee on how to provide this information through Digital interactions. The STP “Commencement” or “Onboarding” is an enhanced and automated process for an employer to receive the information for a new employee:

§ By enabling a digital interaction between the government records and the employer, the employer will (allegedly) receive better information for a new employee.

§ One version is a myGov initiated process for the employee to digitally send TFN Dec and SuperChoice information to the employer. (“Retail”)

§ The second version is that Payroll software will be able to interact with the Government systems to verify the information provided by the employee through systems like payroll employee portals. (“Wholesale”)

STP only deals with the aspects currently achieved through the TFN Dec and SuperChoice forms. STP does not deal with or affect any aspect of an employer’s Fair Work obligations including the provision of the NES document, the determination and advice as to terms of employment and the application of Modern Awards. “Retail” The term retail is being used to describe a service being provided by the government to an employee through myGov. It facilitates the employee authorising the provision of (verified) information by government to the employer. It relies on the ability for the employer to then receive that information. The process would be:

§ Employer provides notice to employee of which ABN relates to their new employer (part of the induction pack)

§ Employee logs into myGov and o selects “started a new job” or similar o enters the employer’s ABN and confirms the employer’s name o reviews their personal information and TFN Dec information o reviews their list of superfunds and nominates which one the employer is to use o authorises myGov to send this information to the employer

This system will only work if either:

1. The employer’s payroll software is able to receive myGov transmission of this information, or


2. The government will provide the information to the employer in an alternate form The employer would (assuming their software has the facility)

§ Have registered their ability to receive myGov submissions § Receive a notification from myGov that an employee has sent information for them § Upload the information into their payroll software

The technical specifications and actual operations of this service are yet to be seen and therefore we are providing our best guess as to the envisaged system. We appreciate the concern that many bookkeepers and employers have expressed that the information provided will be incorrect or require correction. “Wholesale” Wholesale is a system whereby the employer’s payroll software will collect the information from the employee and then seek to verify and then submit the information to government. We are used to a system where the employer obtains all necessary information from a new employee on paper forms (the TFN Dec), which is then submitted to government either by mailing the paper form, or more recently directly through software. Increasingly software enables the collection of all necessary information via an employee portal (computer interaction). The employee can now provide all information including TFN Dec and SuperChoice forms on line and then (hopefully) the software also obtains the necessary declarations and digital signatures to authorise the use and lodgement of the TFN Dec and also the use of the SuperChoice information as nominate. In the envisaged STP program, the software will continue to obtain this information from the employee and the employer’s software will then interact with government systems to verify the TFN Dec information including government debt, visa working conditions, tax thresholds and categories. If the government information is different to the employee provided information, then this system will allow for the government records to be updated or seek verification and correction by the employee. SuperChoice elections will also be automated with the employer’s software notifying government of the election the employee has made and verifying that fund is known in the government records or add the fund to the employee’s profile. In either scenario, the employer must have a system that:

§ Knows they have a new employee to set up § Advises the employee how to and where to send their TFN data (this is a replacement to

providing them with a TFN Dec form today) § The software then needs to know to expect the data to be received and presumably report

or flag it has been received or hasn’t been received (same) § The system (or software) then needs to determine whether that information received is valid

(same process as today) § The system then needs to establish the payroll parameters in the software to pay and tax

the person appropriately (same) § Must still comply with record keeping obligations

Possible automation opportunities:

1. If the employer’s software has an automated system to track that it is expecting a transmission of TFN Dec data and then it could report those still outstanding etc.


2. The myGov system could send a notification to an employer that the information is ready to be collected.

3. The employer must be able to send back to the government the correction to information that has been provided.

When? The current model indicates that the software will be able to submit the new employee information to Government at the first time they are paying the employee, i.e., in conjunction with the employee’s first PayEvent. We are unsure why it is being combined with a PayEvent and believe that many employers will conduct an onboarding process and complete all the entry into the software and then authorise for that information to be sent to the Government. As such business (software) should allow that process. If the information is not being sent until the first pay run, then the business should not be concerned. We have expressed that at no time can the STP system of onboarding prevent an employee being paid. Technical Data Every withholder must be registered for PAYG Withholding with their ABN; some employers have a WPN (Withholder Payer Number). Your software will deal with the conversion of your new employee information into the required taxonomy and in the required data form for submission and interaction with the Government. The data that is being sent, verified, interchanged is the same information that existing laws require you to have when you engage with an employee. Cessation of employment The ATO STP proposal is that when a person’s employment ceases then at the push of the termination button information is submitted to the relevant government agencies.


B: PayEvent The ATO STP proposal is that on the instance of each and every pay run (weekly, fortnightly, monthly etc.) when the “button” is pushed to finalise the pays, send the payslips, authorise and arrange the payment to the employees, that same button will transmit details of that pay run to the ATO. This would need to be implemented by each software company but the ATO system must be able to receive the data.

By enabling and requiring the perpetual reporting of payroll information by an employer to the government, there is an expectation that the following will be achieved:

§ Employers will use software (better business process) § Employers will report PayEvent information every time they pay someone. An employer

must by law provide a payslip to the employee, some of that information will now be provided to the government at the same time.

§ Employers must already comply with the SuperStream system which provides a reporting of the amount of super paid to the funds, now that information will also be provided to Government.

§ Government will therefore see the accruing of PAYGW from an employee’s pay and be able to offset that against the amount paid by that employer, enhancing visibility of the payment and compliance of the employer.

§ Government will see the accruing of the Superannuation Guarantee Contribution amounts at each PayEvent and be able to match that to the amounts of SG paid to the funds by that employer for each employee, enhancing the visibility of super payments and therefore increasing the Government’s ability to follow up employers who are not meeting their obligations.

The ATO will use that information to monitor the employer’s PAYGW pattern and also payment. The ATO will allow payment of SGC and PAYGW at the time of paying the employee. Note this is voluntary.


The ATO concept is that the ATO will prefill PAYGW information on Activity Statements. The Legislation also provides that an employer who is in STP will NOT be required to provide payment summaries to the employees as each employee can obtain their payment summary from their myGov profile. The concept is also that the employee will be able to obtain their payroll information continually from the myGov site including Wage and Super amounts. The ATO will also monitor and provide information about each employees Super Contributions and the annual cap. The process would be:

§ Employer performs payroll as they always have § Employer sends payslips and payment instructions and now the STP message each time

they pay someone WhatDataisBeingSent?Each pay cycle, (weekly, fortnightly, half month, month, occasional, out of cycle), the file will include: Payment Details

§ Period start date § Period end date § Financial year start date § Financial year end date § Final Indicator – used before 14th July each year to indicate information is final (this is not

correctly placed or described in ATO documents at this time) § Payee record count – the number of employees being paid in this PayEvent § Payroll transaction ID – a unique identifier for each STP submission § Payment date § Total PAYGW for the employer for this PayEvent § Total gross payment for the employer for this PayEvent

Intermediary Details If there is an Agent acting on behalf or lodging on behalf of an employer their details must be submitted:

§ ABN § Registered Agent Number § Contact name and details § Name of person making the declaration § Declaration date § Declaration acceptance indicator

Employer’s (Payer’s) details

§ Employer’s identification details ABN or WPN § Employers name and contact details § BMS identification (optional - which pay system for the employer) § Name of the person making the declaration § Declaration date § Declaration acceptance indicator


Employee (Payee) details § Payroll ID § TFN § Contractor ABN (only used to allow VWH agreements) § Payee name, contact address, date of birth § Commencement date (the date they started with the employer – optional) § Cessation date (optional – used to end the relationship with the employer) § Phone and email (optional)

PayEvent details per employee

§ Gross salary and wages YTD value (normal, foreign employment, labour hire, VWH all separately reported)

§ Allowance amounts YTD values and details per type § Deduction amounts YTD values and details per type § PAYGW tax withheld YTD value § YTD amount of SGC accrued (or the YTD value of OTE) § RESC (an optional field and can be used to provide the value only once per year for

inclusion in the Final information for payment summaries) § ETP details (optional but all previous ETP information required if applicable) § RFBA (an optional field and can be used to provide the value only once per year for

inclusion in the Final information for payment summaries) § RFB Exempt Amounts (optional) § CDEP amounts


C: Annual Reporting The ATO will now provide the end of year payment summaries to the employee. This means the employer no longer needs to provide the payment summary physically (or electronically) to each employee. However, the employer will still need to verify their payroll records and then send a message to the ATO to state that the final end of year information provided is correct and able to be used. In effect, no more EMPDUPE files or group certificates, but these are replaced by a final set of PayEvent data. The ATO will then inform the employee that their information is final and ready to be used in a tax return. “Finalisation” replaces the previous submission of EMPDUPE files (copies of Payment Summaries) to the ATO. By sending a “Finalisation” STP submission you will be telling the ATO that the data they now have (as part of that finalisation submission) is to be considered final and can be entered in Income Tax Returns. Technically the “Finalisation” message will be similar to the PayEvent message and the current view is that it will be the same data set. Noting that it may or may not be in conjunction with an actual PayEvent. We envisage that operationally employers and their agents will continue to do what they do now which is do the final pay in their normal cycle and then commence a process of review, verification, correction of data to then submit the (previous EMPDUPE / payment summary) “Finalisation message” to the ATO. RESC and RFB reporting obligations continue and would be provided to the government as part of the “Finalisation” process. Amended Finalisation: you can resubmit a “Finalisation” data for an employee or all employees if an amendment is required after a “Finalisation event” What data is being sent? The current view is that an “update” service will be used to send a “Final” set of data to the ATO. The data will be the same as the PayEvent reported above.


D: Superannuation Payment Reporting Explanatory Memorandum explains:

These amendments require reporting entities to report superannuation contributions that reduce their SG charge percentage that, in turn, will reduce their liability to SG charge for a particular quarter.

As such, the Commissioner may also require the reporting of contributions that exceed the SG charge percentage. Including these contributions will allow the Commissioner to distinguish between an employer’s SG contributions and salary sacrifice amounts (if any), and take account of the fact that employer SG contributions made for one quarter may reduce the charge percentage in an earlier or later quarter. In some cases, reporting entities may also face increased compliance costs separating different contributions. [Schedule 23, item 1, item 3 in the table in subsection 389- 5(1) and subsections 389-5(2) and (3)]

Employers are already subject to a similar obligation to provide contribution information to superannuation funds. Under Part 4A of the Retirement Savings Account Act 1997 and Part 3B of the Superannuation Industry (Supervision) Act 1993 (‘the SuperStream regime’), employers are required to report superannuation contribution information to superannuation funds on the same day the employer makes the contribution to the fund. The information must be given in accordance with certain data and payment standards determined by the Commissioner.

Employers may already use SuperStream-compliant software packages, clearing houses or intermediaries to produce contribution transaction reports. In order to align these STP reporting obligations with an employer’s existing processes under the SuperStream regime, the Commissioner envisages that the information contained in contribution transaction reports would satisfy the employer’s obligations under STP. Whilst, this may involve an employer providing the Commissioner with more information than is required, an employer may wish to report in this way to minimise their compliance costs.

By requiring employers to report such information to the Commissioner on or before the day the contribution is made, the Commissioner will have more timely access to employee-level contribution information than under current arrangements.


You may elect to start being an “STP Employer” at any time after the ATO is ready to receive your information. The ATO must be ready to do the following:

§ Receive STP PayEvent submissions § Receive new employee commencement submissions § Provide payroll information onto an employee’s myGov profile § Provide notification systems to the employee following an end of year finalisation of their

information so they are aware their payment summary is available from myGov § Provide Payment Summaries to the employee via myGov § Provide Payment Summaries to the employee who does not have or is unable to use

myGov In theory, the ATO will be able to do this on 1 July 2017 and therefore you could elect in as of this date. In order for you to do this your software must be ready to do the following:

§ Send STP PayEvent submissions § Send new employee submissions § By 30 June 2018 be able to enter all end of year information and submit the STP

“Finalisation” message You may commence using STP at any time during a payroll year. If you do commence STP, your payroll must submit the YTD payroll information, including the period prior to you entering STP. Therefore, you will not be required to provide payment summaries. You do not have to wait to the start of a new payroll year! If you are setting up payroll for the first time in software and then using that software to enter STP then ensure that the YTD values are being sent to the ATO. If you are swapping software then you have alternate strategies:

1. Ensure that your new payroll software uses the same BMS Unique Software ID as your old software and therefore only produce one set of YTD numbers for each employee

2. Use a different BMS Unique Software ID and therefore you will send two different finalisation messages to the ATO and the employee will receive two different payment summaries from the ATO. One for each software. The old software will have its YTD value until it is no longer used and will need to be finalised. The new software will accumulate YTD only from the date it commenced as the payroll software.

3. Zero out the old YTD number in the old software and bring in the YTD numbers into the new software.

When to Start with STP


Your Reconciliation Processes Don’t Change! The employers records are the source of truth and the PayEvent information submitted to the ATO can be updated at the next submission. However, note that this does not mean a material understatement of PAYGW (or SGC) from a prior period can be just updated in the next STP submission. If you need to increase the amount of PAYGW that has been withheld from a previous PayEvent and that amount should have been reported and paid on a previous activity statement (or for large employers simply have been paid earlier). The same rules apply for disclosure and correction of the previous Activity Statements and payment. Interest will apply from the original due date until the date of payment. The ATO’s records for the employer will be fixed because you will amend your BAS or payment information as you would normally have done. However, in terms of your STP submissions: That error that occurred in a previous STP PayEvent submission has now been fixed in your payroll software and when you make your next STP PayEvent submission, (or possibly not until the “Finalisation message”), the ATO YTD values for the employee will be fixed at that time. Refer ICB resources on how to correct a previous activity statement or a previous large employer payment Note each PayEvent reporting will have YTD values for the employees being paid in that PayEvent and the amounts for the period for the employer. These do NOT have to be reconciled to the ATO systems. That is, you do not have to amend a previous YTD submission and you do not have to amend any period value submission as part of the STP submission process. Why? Because the YTD figures will be fixed with the next PayEvent and the employer figures with the amended BAS. A reconciliation must be performed by the employer at each BAS lodgement for each period to that each BAS reports the correct PAYGW and gross wage for the employer for the period. Similarly, the end of year process would have a reconciliation of the employer’s source of truth and the amount reported on each BAS, (or paid in the case of large employers). Note that the employer’s system is to be the source of truth so that the YTD at employee level is the constantly corrected amount. The employer period values for each PayEvent provides the ATO with the data to add up and prefill the BAS. However, if there has been a change, the employer’s records are the source of truth and therefore the employer would correct the prefill values provided by the ATO.

Reconciliation and Corrections Reconciliation and Corrections


9th January 2017 Policy and Law

§ The employer’s records are the source of truth. § Reconciliation of the employer’s records to the ATO copy of data is not required. § Fair Work obligates an employer to issue correct payslips at the PayEvent. § ATO obligates correct Activity Statements, (or payment information for large employers).

Executive Summary: Recommendation - Corrections The employer’s level of information, (total gross wages and tax withheld for each period), that has been submitted at the time of making each PayEvent report, will need to be correct on the submission of an Activity Statement, (or payment for large employers), and this is taken as the employer submission of a “statement” to the commissioner. Any update to employer level information remains in accordance with existing Activity Statement / payment amendment requirements. The employee specific information (YTD values) will be updated at the next PayEvent or at finalisation. Alternative consideration is a requirement to use the “update” service to amend the employee information being displayed on myGov but only in accordance with Activity Statement lodgement timeframes. This “update” requirement should only apply after the first year of STP. For consideration Should an employer have to correct the employee specific information provided to the ATO at least each quarter? (which would only be required if there was no other PayEvent to correct the information). Should the correction only be on employee request? Legislation The Explanatory Memorandum explains

The framework also utilises the approved form provisions (refersection 388-50), in much the same way as they are used for existing PAYG withholding reporting obligations. The use of the approved form provisions provides the Commissioner with flexibility to defer due dates to better align reporting with an employer’s payroll processes. However, the legislation also limits the flexibility provided by the approved form provisions to specific reportable content. Ordinarily, the approved form provisions would allow the Commissioner to specify the content of a report whereas these amendments limit the content that the Commissioner can require in relation to specific amounts. This is designed to provide reporting entities and payroll system designers a high level of certainty and stability about the amounts to be reported under STP.

ICB Submission Reconciliation & Correction


Background - Process in STP The employer will submit to the ATO as part of STP

§ The YTD values of payroll information for each employee paid in a PayEvent § The Period amounts of Gross Wage and Tax Withheld for each PayEvent, and § Notification of the “Final” status of an employee’s information for each financial year.

The ATO will § Display the most recent YTD values for each employee in the employee’s personal myGov

Profile (with the date those values were submitted), § Aggregate each of the employer level period amounts (for each PayEvent) submitted and

attributable to each Activity Statement period to prefill the employers W1 and W2 values, § Provide the employee with the Payment Summary as a result of the “Final” information

notification, and § Conduct and enquiry or compliance program based on the information

Scenario A: Correction before BAS If an employer changes an amount previously reported in a PayEvent within the same Activity Statement period before the Activity Statement has been submitted. The employee’s YTD values will be updated in the ATO information in one of:

§ The next PayEvent for the employee will provide the updated YTD values § The “Finalisation message” will provide the correct final YTD values for the employee (this

may occur as part of the end of year process or if the employee has not been included in a PayEvent since the change)

§ The employer may choose to submit an “update” event message to alter the current values for the employee, or

§ The law and taxonomy allows for a Full File Replacement (FFR) which may also be used to affect the change.

In this instance the employee’s YTD values will be updated. This should be considered acceptable and no further action or consequence should apply. This update can happen at any time including up to the point of finalisation Alternatively, it may be considered that the employer should use an “update” event to correct a specific employee’s record at least once a quarter or maybe only at employee request if there has not been a PayEvent to affect the correction. We note this would be an increased obligation (an extra step) in needing to report to the ATO, however we also note that the employer already has an obligation to provide accurate information to the employee, therefore any correction should already have been performed in the system and notified to the employee. Accordingly, the notification of the corrected values to the ATO through the “update” event appears feasible with minimal impact. The period values for the employer are unlikely to have been updated as the change is not reported within a future normal PayEvent. We submit that this is acceptable. The correction will occur as the employer must alter the prefill Activity Statement values to be the correct reporting of W1 and W2 for the respective period It is the Activity Statement that should continue to be considered the “making of a statement” to the Commissioner. As no Activity Statement has been submitted for this period there is no need to amend an activity statement. The same rules would apply to that activity statement as under current requirements.


Large Employers For a large employer who has a weekly payment obligation for the amount of PAYGW the consequence of an increase to an amount of PAYGW is more likely to require amendment to a previously reported or paid amount of PAYGW. We propose the same regime would apply in an STP world as it did previously in terms of the employers PAYGW amounts. Same interest regime, same amended reporting regime. Scenario B: Correction after BAS lodged If an employer changes an amount previously reported in a PayEvent after the Activity Statement for the relevant period has been submitted. The employee’s YTD information will be updated in:

§ The next PayEvent § The “Finalisation message” § A “update” message or § Full File Replacement (FFR)

This is acceptable and no further action or consequence should apply. This update can happen at any time including up to the point of finalisation. The employer’s reporting of W1 and W2 for this past period has been submitted in the lodgement of the Activity Statement. The employer must now alter the activity statement for the relevant period including paying any additional amount and noting the likely imposition of interest and possibly penalties. This is the same regime as currently in relation to activity statement amendments. STP report and “False or Misleading Statements” It has been the stated intention to allow the STP report of the YTD values to be corrected at the next PayEvent. Therefore, the Commissioner will need to state that the “grace period” (as required in the Act) for correcting a previous STP report of YTD value for an employee is in accordance with the above comments:

§ The next PayEvent § The “finalisation message” § An “update” message, or § As part of a full file replacement

We restate that the employer amounts of Gross Wages and Tax Withheld for each reporting period (Activity Statements for Small and Medium withholders) and weekly payment advice (for large withholders) will be corrected and be subject to the same amendment requirements as the existing Activity Statement and payment advice notifications. No part of this paper permits or is intended to create an opening for the employer to provide false or misleading statements to the commissioner as a STP PayEvent or any other STP obligation. All employers should be permitted to make corrections to payroll in accordance with this paper however all existing obligations of an employer in relation to payroll and correct timing of withholding PAYGW and accruing of SG apply.


“Update” message Should be the same taxonomy as a PayEvent message and it updates all values for the employee but it does not have any consequence for the employer’s values. When does an employer need to be correct? Fair Work sets the requirements for provision of payslips to the employee, noting there is currently no requirement to display YTD information. The pay slip provides the period’s payment information. A requirement is also to retain the details of what has been paid when, i.e., each pay slip’s details; accordingly, the YTD information can then be determined for the employer to meet their payment summary obligation. It is logical that a pay slip should be correct. It is logical that if a pay slip is incorrect that the employer should correct that pay slip. It is an ATO requirement to withhold the correct amount of tax from payments made to employees and accrue and then pay the correct amount of SG. Therefore, currently the employer must issue pay slips and correct those pay slips when an issue is brought to their attention and withhold PAYGW and if any alteration effects that PAYGW amount they must alter the withheld amount and report/pay that alteration in accordance with Activity Statement requirements. In an STP environment, despite the employer reporting a PayEvent to the ATO which may now not be correct, we propose that this should not necessarily increase the reporting requirement of the employer ATO, i.e., no additional step that creates an encumbrance. Therefore, we propose that in an STP environment the employer must:

§ Continue to correct their own employer records for payroll § Correct any pay slips (in accordance with Fair Work) and provide them to the employee § Correct any activity statement reporting in accordance with the current framework § Correct the employee specific information by the time of “Finalisation”

We note that software may make this issue redundant by performing an automated “update” service following any alteration. Refer below comment to Software Companies. If the alternative consideration (requiring an “update” to corrected amounts at least once per Activity Statement reporting period) is implemented, we strongly recommend this is not brought in until after 20 June 2019, (i.e. one year following the implementation of STP). Timing of corrections – what is corrected when? If it becomes an expectation, or the behaviour of the employer is, to lodge an “update” following any correction to a past PayEvent, then we note that the update will be to the current values of YTD information. Therefore, the update may not be noted in STP reports within the relevant activity statement period. Typically for a quarterly activity statement reported if payroll is reviewed and a correction made for pay events during that period, it is occurring following one or more other PayEvents for that employee. Accordingly, the ATO has been advised (through an STP report) of more recent YTD values. Following the correction in the past period, in order to maintain logic of YTD value submissions in the chronological sequence, the update service would be dated today (the date of submission of the updated information) and have the current (as of today following the correction but also following any other PayEvents since the date of the PayEvent that has now been corrected).


Reconciliation We again submit to the ATO that employers conduct reconciliation of their payroll in accord with natural business systems and in accordance with considerations of materiality and meeting their various Fair Work, State Revenue Office, Workers Compensation and ATO reporting requirements. They conduct a process of checking, verification, amendment and reconciliation at the appropriate times. Accordingly, we appreciate that STP has been designed on the principle of the employer’s records being the source of truth and that any amendment will occur in the employer’s system. That employer’s system will then report any amended data to the ATO through the mechanisms discussed above (Activity Statements and “updates” or “PayEvent” reporting). It remains inappropriate and counter to the Minister’s (and Parliament’s) intention to ever have the concept of “Reconciliation” to the ATO records as a requirement. We understand that this does not preclude any action of the ATO to seek verification of current employer values and the calculation thereof. We refer to separate papers on ATO compliance strategy. Questions and discussion Do we have or do we need an ability in STP to submit an alteration or additional employer’s period value for gross payments or tax withheld? ICB would suggest not as they can alter it at the time of lodging an Activity Statement. Does the employer have to submit a period value for the amount of SG accrued during the period? I haven’t seen this in the taxonomies nor believe it has been discussed? To be consistent with the gross wage and tax withheld concept there is logic that the SG accrual amount also be reported. Note ICB policy position would be that this should NOT be reported separately. The ATO has the ability to take the total YTD values of all employees as at the end of each quarter and compare that to the values at the start of the quarter and determine how much SG has been accrued. What is the ATO compliance strategy in relation to SG given the type of data being received? YTD values of SG per employee at each PayEvent and payment of SG through SuperStream? What techniques (data analysis) is the ATO performing to detect poor behaviour by employers? These questions are relevant to the “corrections” discussion as the status of information determines any ATO enquiry. Refer separate ICB submission on ATO compliance strategy. Noting: The employer does not need to reconcile the ATO information from STP to the employer’s information. The employer may periodically update the ATO information to the current employer’s information. Should different thresholds result in different correction requirements? What if the amount is significant? Should there ever be any requirement to rapidly amend the information available to an employee through myGov? We propose that the answer is No. Request to Software Companies (specifically in relation to corrections framework) When we make a correction to payroll that has previously been reported in a PayEvent we request you provide us with a system that:


§ Sends an update event for the relevant employee with the “current” revised YTD values (note this is not a change to the past PayEvent this is to update the current YTD values based on a change that happened in history)

A: When it is within an unlodged activity statement period § Ensure the change is reflected in the activity statement reporting B: When it is in a past lodged activity statement period § Alert the employer to the need to lodge an amended activity statement and provide the

amended activity statement values. Explanation to Employers Under STP you will be perpetually reporting PayEvent information to the ATO being the current value of YTD amount for each employee and for each PayEvent your amount of total gross wages and tax withheld. Your obligation is to have correct records and provide your employees with correct information. You also must continue to provide the ATO with correct payroll reporting on your Activity Statements (or for large employers with your weekly PAYGW payment system). If you have made a mistake In accordance with normal business practice you would need to:

§ Provide the employee with corrected payslips § Amend any previous activity statement for the corrected values

In relation to your STP reports the employee’s information will be updated with their next PayEvent, therefore there is nothing else required of you. If the employee will not receive a future PayEvent you may consider submitting an “update” to their STP YTD values. We note that you will still be required to submit the “final” values for each employee as part of your end of year process.


1. Refunds can be withheld

The commissioner may retain a refund due to you, where you have not lodged an STP report. The commissioner must form a reasonable belief that you have NOT lodged prior to being able to withhold that refund. Any withholding of any refund must be notified to you within 14 days of when the refund amount was first known. The refund may be withheld until any of:

§ The relevant STP report is provided § The ATO becomes satisfied that no report was required § The ATO is satisfied that there is no PAYGW liability § The ATO ascertains the entity’s total PAYGW liability

2. Penalties can apply

Subject to what becomes the agreed status of each PayEvent submission, it is conceivable that the existing penalty regime for late lodgement will apply. The legislation allows a 12-month transitional relief from any such penalties. Greater visibility of compliance behaviour will be good. The ICB view includes:

§ Rapid follow-up of non-payment would be required. § Greater visibility of compliance behaviour is a positive

What trade-off is to be provided to all those compliant employers who do and have been meeting their obligations? They will now have further reporting obligations to endure so that the system will endeavour to enforce compliance on the others. There must be certainty provided to the business that complies:

i. As to the style of queries that will be raised ii. The ease of being able to respond to any queries iii. That there will be no automatic adjustments by the ato iv. Avoidance of a system that will require more formal objection routines v. Easy and accepted adjustments to prior reports without needing to explain to the ato

This matter is still being discussed. ICB have provided a concept paper (copy follows) to commence the discussion.

Compliance Action by the ATO


9th January 2017 Policy The employer’s records are the source of truth. Reconciliation of the employer’s records to the ATO copy of data is not required. Fair Work obligates an employer to issue correct payslips at the PayEvent. ATO obligates correct Activity Statements (payment information for large employers). Monitoring of an employer’s PAYGW, SGC and STP reporting compliance will occur. Compliance actions by the ATO must take place. Executive Summary – Recommendation - Compliance An automated compliance strategy. Based on known employers. Direct communication of information that all employers must consider. Webform / Webservice / SBR Service submission by each employer as to:

§ Whether they are a substantial employer § If so, advise their normal payment cycle (weekly, fortnightly, monthly, adhoc)

Computerised review of the employers to follow up: § Substantial employer status, then § Receipt of expected STP reports, then § Receipt of expected Activity Statements / payments, then § Anomalies in ccruals vs payments, and § “Final” notification

Prompt follow up of all requirements. Background - Process The employer will submit to the ATO as part of STP:

§ The YTD values of payroll information for each employee paid in a PayEvent § The period amounts of Gross Wage and Tax Withheld for each PayEvent § Notification of the “Final” status of an employee’s information for each financial year.

The ATO will § Display the most recent YTD values for each employee in the employee’s personal myGov

Profile (with the date those values were submitted), and § Aggregate each of the employer level period amounts (for each PayEvent) submitted and

attributable to each Activity Statement period to prefill the employers W1 and W2 values § Provide the employee with the Payment Summary as a result of the “Final” information

notification, and § Conduct an enquiry or compliance program based on the information § Monitor the submission of STP reports, noting the timeframe expected and achieved § Monitor the PAYGW withheld and payments § Monitor the SGC accrued and then paid

The employers information (total gross wages and tax withheld for each period) that has been submitted will need to be correct on the submission of an Activity Statement (or payment for large employers) and this is taken as the employer submission of a “Statement” to the commissioner. Any update to employer level information remains in accordance with existing Activity Statement amendment requirements.

ICB Submission – ATO Compliance Actions


The employee specific information will be updated at the next PayEvent or at finalisation. Alternative consideration is a requirement to use the “update” service to amend the employee information being displayed on myGov but only in accordance with Activity Statement lodgement timeframes. Background - STP report and “False or Misleading Statements” It has been the stated intention to allow the STP report of the YTD values to be corrected at the next PayEvent. Therefore, the Commissioner will need to state that the “grace period” (as required in the Act) for correcting a previous STP report of YTD value for an employee is in accordance with the above comments:

§ The next PayEvent § The “finalisation message” § An “update” message, or § as part of a full file replacement

We restate that the employer amounts of gross wages and tax withheld for each reporting period (Activity Statements for Small and Medium withholders) and weekly payment advice (for large withholders) will be corrected and be subject to the same amendment requirements as the existing Activity Statement and payment advice notifications. No part of this paper permits or is intended to create an opening for the employer to provide false or misleading statements to the commissioner as a STP PayEvent or any other STP obligation. All employers should be permitted to make corrections to payroll in accordance with this paper; however, all existing obligations of an employer in relation to payroll and correct timing of withholding PAYGW and accruing of SG apply. Background - When does an employer need to be correct? Fair Work sets the requirements for provision of payslips to the employee, noting there is currently no requirement to display YTD information. The pay slip provides the period’s payment information. A requirement is also to retain the details of what has been paid when i.e. each payslips details, accordingly the YTD information can then be determined for the employer to meet their payment summary obligation. It is logical that a pay slip should be correct. It is logical that if a pay slip is incorrect that the employer should correct that pay slip. It is an ATO requirement to withhold the correct amount of tax from payments made to employees and accrue and then pay the correct amount of SG. Therefore, currently the employer must issue pay slips and correct those pay slips when an issue is brought to their attention and withhold PAYGW and if any alteration affects that PAYGW amount they must alter the withheld amount and report/pay that alteration in accordance with Activity Statement requirements. In an STP environment, despite the employer reporting a PayEvent to the ATO which may now not be correct, we propose that this should not necessarily increase the reporting requirement of the employer ATO, i.e. no additional step that creates an encumbrance. Therefore, we propose that in an STP environment the employer must

§ Continue to correct their own employer records for payroll. § Correct any payslips (in accordance with fair work) and provide them to the employee.


§ Correct any activity statement reporting in accordance with the current framework. § Correct the employee specific information by the time of “Finalisation”.

We note that software may make this issue redundant by performing an automated “update” service following any alteration. If the alternative consideration (requiring an “update” to corrected amounts at least once per Activity Statement reporting period) is implemented, we strongly recommend this is not brought in until after 20 June 2019 (i.e., one year following the implementation of STP). Background - Timing of corrections – what is corrected when? If it becomes an expectation, or the behaviour of the employer is, to lodge an “update” following any correction to a past PayEvent then we note that the update will be to the Current values of YTD information. Therefore, the update may not be noted in STP reports within the relevant activity statement period. Typically for a quarterly activity statement reported if payroll is reviewed and a correction made for pay events during that period, it is occurring following one or more other PayEvents for that employee. Accordingly, the ATO has been advised, (through an STP report), of more recent YTD values. Following the correction in the past period, in order to maintain logic of YTD value submissions in the chronological sequence, the update service would be dated today, (the date of submission of the updated information), and have the current value, (as of today following the correction but also following any other PayEvents since the date of the PayEvent that has now been corrected). Background - Reconciliation We again submit to the ATO that employers conduct reconciliation of their payroll in accord with natural business systems and in accordance with considerations of materiality and meeting their various Fair Work, State Revenue Office, Workers Compensation and ATO reporting requirements. They conduct a process of checking, verification, amendment and reconciliation at the appropriate times. Accordingly, we appreciate that STP has been designed on the principle of the employer’s records being the source of truth and that any amendment will occur in the employer’s system. That employer’s system will then report any amended data to the ATO through the mechanisms discussed above (Activity Statements and “updates” or “PayEvent” reporting). It remains inappropriate and counter to the Minister’s (and Parliament’s) intention to ever have the concept of “Reconciliation” to the ATO records as a requirement. We understand that this does not preclude any action of the ATO to seek verification of current employer values and the calculation thereof. We refer to separate papers on ATO compliance strategy. Proposal - An Automated Compliance Strategy The STP compliance program lends itself to be automated. The ATO is already aware of every registered employer therefore you have the contact database. We recommend you do NOT exhaust resources on extensive public communication campaign but simply provide direct communication to employers that outline their responsibilities. A number of direct communication to employers and their Agents would appear appropriate and required.


We propose that through the use of computerised techniques: § Scheduled and automated email § Webform (alternatively SBR submitted) interactions

The information communication program and the enquiry/compliance actions can commence via email. The emails would contain information and also links to webforms which informs the employer registration database. Maybe this links off the ABR/ABN registration of the PAYGW obligation. Maybe this STP database has to be ancillary at this time, integration with ABR and inclusion in ABR functionality would appear to be logical. Initial webform required of each employer to advise that

1. They are or are not a substantial employer. 2. If they are what their normal pay cycle is i.e., weekly, fortnightly, monthly

This enables the STP monitoring to be established. In addition to the webform service an SBR service for software to provide the same declarations or webservices interaction (subject to software consultation). Answering the questions of how will the ATO know whether to follow up an employer or not:

§ How will the ATO know to expect the frequency of reports? o Recommend webform declaration

§ How will the ATO know of seasonal reporting only or a change in reporting frequency? o Recommend webform declaration)

This information is required in order for the ATO system to be able to know who to monitor and what to expect. The ATO system monitors and generates auto responses – automated email follow up processes. Ultimately if the auto responses and webforms do not receive responses from the employer, default notifications will be provided to the ATO to initiate phone contact or then to generate the further follow up action. Are they a substantial employer? Employers to advise via an easy website registration form. Email each employer a request to advise whether they are a substantial employer. If they are, then to obtain an estimation of the normal payroll cycle i.e. how often an STP report should be received.

1. New registration of an employer

a. Immediate provision of induction pack on STP and other ATO related obligations As a whole of Government approach, consider including Fair Work, State Revenue Office and Workers Compensation matters. b. Provision of link to online form to indicate they are or not a substantial employer. c. Failing any response the ATO system flags the employer for STP monitoring. d. Email follow up at time of first Activity Statement obligation:

o As to STP reports need to be received o As to setting the expectation about receiving an Activity Statement

e. Phone follow up if first activity statement with a PAYGW obligation not received as of due date.


2. Validation that they are NOT a substantial employer post 30 June 2018, if no other declaration received. (Consider an annual follow up declaration but maybe based only on observed values). a. Following the initial information regime about STP throughout 1 July 2017 to 30 June

2018. b. A follow up request for completion of an online declaration by employers that they are

or are NOT a substantial employer. c. Any employers who do not advise enter a follow up regime:

i. 10 July 2018 email to: 1. All employers who have not lodged an STP report, or 2. Have not responded to the declaration.

(With a website link to advise they are or not a substantial employer);ote if an STP report lodged then flag is set accordingly.

ii. 31 July second follow up. iii. 31 August written demand.

3. First period of becoming a substantial employer (20 or more headcount):

ATO observed through SuperStream contribution messages for number of employees. ATO conducts an internal system review in April and a. Immediately emails to induct them into STP reporting process. b. ATO system flags employer for STP monitoring commencing following July.

Employers who have a STP obligation

4. No STP reports received? Following a nomination that they are due to report or the first Activity Statement lodgement or passing of the lodgement due date, without any STP reports: a. Immediate email message to business and any agent requesting commencement of

STP reporting. To be sent within 30 days of expected first report. b. +20 days: Follow up phone call. c. +30 days: Demand notice (withdrawn if employer complies). d. +60 days: Legal action.

5. STP reports commenced but then ceased, no notification provided: a. Email to follow up after a month. b. Once regular pattern (weekly or fortnightly) established then follow up according to

the pattern. c. Follow up seeks explanation or declaration of no lodgement required (website form).

6. Seasonal employer only:

a. Can declare that they are seasonal or occasional employers and therefore no systematic follow up is expected.

7. No SGC Accrual If the employer is reporting and it is observed that no SGC is being reported. Based on an employee by employee review if an employee has received more than $450 gross wage in a month and no SGC accrual is observed then the system automatically ends out an enquiry as to why. A webform response could be created whereby the employer is provided with a link to a form specific to their record enabling them to explain the basis for no SGC.


Alternatively, provide a declaration that they have amended their system and will commence reporting. Alternatively, confirm they have amended their system, caught up any SGC owing and are now accrue correctly.

8. No SGC Payments If the ATO is seeing SGC accrual per #7 above, but no SGC amounts are being paid (payments not reported):

a) ATO systems perform the review following the end of each quarter and generates a please explain notice immediately to the employer.

b) A webform link response would make sense. c) Intervention subject to style of response received.

However, we would encourage immediate and strong follow up and intervention MUST take place. Details to be discussed.

9. No PAYGW Accrual Same concept as for #7 above re SGC.

10. No PAYGW Payments If no amounts reported on Activity Statements and therefore no payment, or no payment by large employer then same follow up strategy as in #8.

11. SGC matching accrual is not being paid Similar to #7 and #8 above, however, the ATO computer performs data analysis of the amount of SG accruals occurring during each quarter and the amount of SG payments made for that quarter (not matching issues) and within thresholds monitors a constant payment cycle to offset the accruals. If there is continual increase in the amount accrued (noting timing issues) above the payment amount, SGC enquiry as to reasons followed up by more active investigation.

12. PAYGW matching accrual is not being paid If the employer alters the prefill amount, this is not prima facie to be considered an issue. However, if the employer reduces the prefill amount by a material amount, an enquiry should be raised. If an accrual has been reported but no payment or no activity statement is lodged immediate follow up of the required activity statement should be instigated.

13. “Final” message The ATO should issue information pack prior to the 30 June in relation to the “Final” message obligations. If an STP employer has not submitted a “Final” message for all relevant employees by the 14th July a gentle reminder should be issued.

If no “Final” message is received by 28th August, then a notice of requirement to lodge should be issued. Then compliance activity.


The Explanatory memorandum explains:

A key area where the legislation provides flexibility is the broad powers given to the Commissioner to exempt entities from reporting under STP and defer the start dates for classes of entities by legislative instrument. This ensures the Commissioner can administratively manage the concerns of a range of entities that may have difficulties in transitioning to STP reporting.

Submitting STP PayEvent information every pay run – or not Concept Your software will be perpetually connected to the internet (if not browser based) and therefore the software will submit the information to the ATO at the same time as pay slips are created and the payment instructions to the bank are created/sent. If you use software that is only intermittently connected to the internet, then that software will need to create the submission and queue it for transmission when the internet is available. The same “intermittent” concept would apply to regional people who need to travel “into town” in order to have internet connectivity. Alternatively, it is recognised that some employers are seasonal or are not computerised. If you employ, there are requirements as to employment records and obligations and these will not change. However, that style of employer may currently calculate and report their payroll as part of their periodic BAS process. It is envisaged that the ATO will be developing alternate systems that do not cause such an employer to incur unwarranted expenses in order to report under STP. It is likely they will need to apply to be included in an “exemption” from PayEvent reporting but would then be required to report at least quarterly, probably monthly through other means. Employers may have their STP reports transmitted as a service provided by their bookkeeper or another payroll service provider. The Agent would have the ability to lodge on behalf of employers from their own practice system. Alternatively, a concept is to use another government bureau service (maybe like Australia Post) where an employer could submit their information from their lodgement services. We note that STP is considered part of the Government’s digital by default policy. We also note that an employer’s obligations are more easily met with the implementation of appropriate payroll software solutions.

What if You Cannot Report to STP?


Implementation plans Keep up to date with information from the software companies plans and implementation timeline at our STP webpage: www.icb.org.au/singletouchpayroll ICB expectations We expect the software companies to continue on their paths of improving the payroll processing experience for us as Bookkeepers and for businesses. The Single Touch Payroll initiative is tapping into the good work that has been happening for some time. We already have employee portals, electronic payslips, electronic payment summaries, downloadable TFN Decs, SuperStream calculations and gateways, electronic signatures and authorisation processes. Not all of these are perfect and we expect the software to continue improving their processes so that we can cut the friction out of the payroll process. We expect that the software companies will implement STP by 30 June 2018 when it is required by the “Substantial” employers. We expect that they will make it easy and it will make sense for you to adopt STP. MYOB Actively engaged in the consultations and design of STP. Actively implementing STP into all its products with payroll solutions. Current plans are to enable services following the ATO technology being available and certainly before any employer is required to provide any report to the ATO. For most MYOB clients, STP will happen from within the product with minimal impact upon the employer or employee. Xero Xero advise: “Xero is working closely with the ATO on the roll out of Single Touch Payroll. We will ensure our users are compliant with all new ATO regulations surrounding the changes. We are creating communications to our users through the Xero blog which will be posted in the coming months to ensure they understand the new requirements.” Reckon Reckon are also engaged with the ATO STP initiative and have commenced design activity for the required amendment to the range of Reckon payroll products. Intuit KeyPay, the provider of payroll in QBO advises: “KeyPay will be Single Touch Payroll compliant as per the schedule set out by the Australian Tax Office - the KeyPay user does not need to worry about it”. Others The Australian Business Software Industry Association (ABSIA) is very involved in discussions with the ATO around the design and implementation strategies.

Software Companies


Who is allowed to do what in a STP world? Previously a Bookkeeper or Payroll Officer would calculate the payroll and then seek management authorisation to process the pays based on results of the payroll process. This authorisation would typically approve the amounts to be paid, the issue of the pay slips and providing the instructions to the bank to make the payments. There was no government submission of the data in the previous payroll process. We note that even today any person performing the calculation of payroll should be obtaining authorisation for payment following the calculations. In an STP world all of the same processes happen. However, the difference is that now the ATO is receiving data in an approved form, (even though that approved form is the specified electronic data form). Typically, when submitting a form to the ATO it has to be verified as being true and correct. The law has provided the ability for the ATO to allow correction of a PayEvent report at a later time. This process has yet to be finalised; however, it is envisaged that a later PayEvent where the YTD numbers are replaced would be accepted or possibly the “finalisation” message which is when the numbers are verified and advised as ready for payment summary purposes. (Noting that if information provided on a BAS is incorrect or for a large withholder a previous payment has been incorrect then that BAS or payment notification will need to be amended within the current legal framework). Therefore, it is proposed that the submission of the STP “approved form” (data) does need to be correct in the same way that the pay to the employee needs to be correct; however, it can be amended in the employer’s system (the source of truth) and the data corrected with the next submission. The submission of any STP data needs to be authorised:

§ The appropriate management person of the employer. § If lodged by an Agent then they must be legally allowed to submit documents on behalf of a

client, (i.e. be a registered tax or BAS agent). § The software must use today’s cloud authentication systems to lodge the STP submissions.

Intermediaries / Registered Agents STP acknowledges that many intermediaries process payroll on behalf of employers. STP works in conjunction with the law (TASA and TAA) that require appropriate authorisations to be in place, declarations to be made by both employers and the intermediary in relation to any submission. The PayEvent submission requires intermediaries to be identified by both ABN and Registered Agent Number. To be advised At the time of publication, the status of an STP submission for the purposes of the TASA 2009 is still to be determined.

Authorisation Authorisation & Declarations


1. Voluntary Withholding Agreements (VWH)

If a business has contractors subject to a VWH agreement administered in a payroll system, in order to withhold and report the PAYGW amounts, then they MAY also report those amounts in an STP PayEvent submission. It is not a requirement. It is recognised that many contractors, even those subject to super, are NOT administered through payroll and hence it is not possible to report contractor payments nor super for contractors through STP.

2. Super Paid for Contractors It is recognised that many contractors, even those subject to super are NOT administered through payroll and hence it is not possible to report contractor payments nor super for contractors through STP. It is not part of STP requirements

3. Labour Hire Agreements If the employer has payroll and withholding responsibility for the payments to employees under labour hire agreements then they are included in STP and are separately identified. If they are administered through the employer’s payroll systems.

4. Full File Replacement It is possible to completely replace the most recent STP submission or arguably a previous STP submission. This is an unnecessary process unless the file was somehow corrupted and even then it would only be the most recent file.

5. End of Financial Year – Which Year? Each PayEvent is dated and also states which payroll year it belongs to. Accordingly, it maybe that you have not “closed” last payroll year but you have a PayEvent to run and report in the new financial year. Your software must appropriately indicate the correct financial year for the new PayEvent. Then you may be processing and finalising the previous financial year; your software must indicate that you are finalising the previous financial year.

6. End of Financial year – What Changed? In effect, nothing. You still need to do all your previous verification processes. The previous EMPDUPE file transmission to the ATO is replaced by a STP transmission of the “Final” data. You do not have to provide employees with the ATO format of Payment Summary. Arguably you do not have to provide anything to the employees at the end of the year. We expect most employers will provide a report of some form which may include explanation that their payment summary is available on myGov.

Bookkeeping Process Impacts


STP will continue to develop. The current project commenced consultations approximately three years ago. Therefore, we will use a series of statements to keep you up-to-date and informed as to the current status of STP

Good Work in Progress Work Required Urgent Work Required

1. Legislation for Stage One. Complete

It has received Royal Assent (16th September 2016). It imposes PayEvent reporting on substantial employers as from 1 July 2018. It enables other STP developments.

2. Legislative Instruments to Describe the Reporting Discussion

The design is in consultation Drafts of the design exist and are reasonably well developed, but…..the LIs prescribe the data to be sent and commit the ATO to a formal process of any data requests.

3. ATO Guidance to Employers Alpha draft has been discussed

Significant work is required for the regulator to correctly provide its information to employers.

4. ATO Guidance to ATO Staff Unseen

Internal implementation guides are required to explain how the ATO will process and react to the STP data. This includes the compliance framework.

5. Technical Specifications for Software Companies Beta published

There is significant work required to provide adequate technical documentation

6. ATO Technical Readiness Discussed We have received one presentation on the ATO plans for them to be technically ready to receive and appropriately process, let alone deliver their output from the STP data they will receive. 7. Payroll Software Readiness Engaged Software companies are involved in the discussions and are pushing the ATO for appropriate but complete technical specifications

8. Employer Readiness Information available

In many ways there is very little for employers to do. Until the ATO has finalised the implementation and therefore its technical requirements, the software cannot implement the system and then explain to employers any impact. Employers should be aware that there is work being done by software and then the advisors to minimise any operational disruption from STP.

Status ICB Confidence Level


There is significant implementation work yet to be performed, predominantly by the ATO. Then the implementation information that the ATO must provide to software companies and employers in order for STP to commence. This table shows the level of confidence ICB has that each of the practical impacts of STP will be achieved

Completed On Schedule Not convinced No evidence

1. PayEvent reporting Very concerned

2. Prefill of the BAS from PayEvent information Not convinced

3. Commencement of an employee through myGov Maybe in 2019

4. Commencement of employee through software ATO dependent

5. Payment Summaries provided by the ATO Nothing has been seen

6. Visibility of payroll information in myGov Nothing has been seen

7. Visibility of super information in myGov Nothing has been seen

8. ATO Compliance Program – soft touch enquiry Nothing has been seen

9. ATO Compliance Program – catch the crooks Nothing has been seen

This is current as of 3rd January 2017. The confidence level table is updated at: www.icb.org.au/singletouchpayroll

All updates available at: www.icb.org.au/STP


What if the person doesn’t have any internet/ good internet / enough internet to be constantly sending information to the ATO?

Preliminary response: The legislation and administration of the system will allow exceptions where required.

What if the pay information needs to be changed?

Preliminary response: The system is being designed for amendment to information previously submitted.

What action will the ATO take if they get some information they don’t like?

Preliminary response: We are lobbying the Government and the ATO to have an approach that they will make enquiries softly first before initiating any burdensome investigations. The ATO seem to be favourably considering this approach. Such a soft approach is consistent with the current philosophy of the ATO.

We also wonder how many businesses will be interested in sending this information to government all the time?

Preliminary response: The argument is that all businesses will be comfortable with this burden if the government is doing something about the employer who is obviously not complying. This increased reporting MUST result in a level playing field.

Question Answer

Not all employees have computers to have access to myGov?

The concept is that the ATO will still publish the Payment Summary to the employee by another means. The Payment Summary information will still be available to their agent via prefill of a tax return.

Is there any suggestion that TFNs need to be entered and lodged before the pay event can be reported?

The law has not changed. The obligation on the employer to obtain the TFN Dec is the same. The employer’s obligation and ability to pay the employee as part of the first payroll run has not changed. If the TFN has not been provided the employer can still pay them and use the temporary TFN numbers or withhold the no TFN amount. The STP data to the ATO will add a new employee with a TFN to that employer as well as expecting the full TFN Dec. This process may change as it is one of the areas everyone believes there can be improvements.

STP - Frequently Asked Questions


What if they do not have a TFN yet? Recommend to use TFN 111 111 111, which informs the ATO that the employee has applied for a TFN.

Can you opt in STP anytime also as employer with less than 20 employees?

Yes. Noting: The system has not been imposed on small employers until it is up and running and the benefits can be realised.

What about accountants that decide when they are doing the financials to pay directors via journal entries - how will this be captured?

Once the employer is in STP they will need to submit payroll information via a report of STP information. The “Adjustment” to payroll would need to be sent to the ATO. The accountant will be required to send a new PayEvent finalising the entities EOY payroll wages for those directors only.

Can the last PayEvent include only those employees with changes to ensure annual payment summaries are not re-sent to employees with no change?

The employer MUST send a “Final” PayEvent with the “Final” flag turned on for each employee paid during the year. As such the “Payment Summary” will not be sent to the employee in the ATO dream of the new world. They will make the payroll information available through myGov and the employee will be able to obtain it from there. They will see when it has been marked final.

How can we incorporate to the STP the sitting fee receive by directors in every meeting they are attending?

Required to add directors to payroll to include in STP PayEvent.

Do we think the ATO will issue Payment Summaries throughout the year (for overseas workers returning home)?

ICB understanding the ATO will issue annual payment summaries during the year. There is a series of changes going on at the moment about backpackers and the employers obligations. A topic for another time when the system has been finalised. The ATO thought they would impose a new system as of 1 January 2017 but all payroll providers are telling them it is nigh on impossible to implement. Therefore, if an employee resigns and starts another job within the financial year, the employee will receive 2 annual payment summaries at end of year.

Question, if the employee has been flagged with a termination, will the ATO send an annual payment summary at the time of termination or at end of year

The information will be available on myGov as soon as it is notified by the employer.


How will the ATO know someone has finished working for an employer?

Upon commencement, the start date is notified to the ATO, alternatively the first pay event will include the start and finish dates of the pay period and therefore the ATO will know when they started.

Upon termination: the inclusion of any termination type payments “unused annual leave” or ETPs and the date of payment will be sent to the ATO in the PayEvent data.

I currently do all payroll for 1 client including payment summaries but I send the electronic file to the accountant to lodge at the end of year. Does this mean that I would now be doing STP not the accountant?

STP data will be sent directly from the payroll software as part of the natural payment process. The concept is an additional work.

The “Payment Summary” process is replaced by a “Finalisation” process. So, before you send the “Final” flags through to the ATO, you would get the accountant’s sign off.

We envisage that their will evolve the ability for the “Final” event to be sent by a different system than all the previous STP PayEvents for the same employer,i.e., the accountant’s system. We are unaware that any such system exists for the STP world yet.

Regarding directors’ fees, apart from PAYG they should also incur super guarantee and payroll tax thus should they have to be done before June super and payroll tax are lodged?

Yes, this has always been issue for directors’ fees being paid after the end of the financial year.

In theory, nothing changes and the back payments need to be accounted for in the correct period,with the correct SG Charge.

As the info submitted is YTD info, any adjustments that may have been made i.e. midweek, will be caught up withwhen next pay-event will get submitted?

Yes, that is right, a new PayEvent will be sent to the ATO on the next pay run which would include the adjustment.

Each pay run is YTD info so that adjustments are automatically caught. No adjustment notification is necessary unless it is a change AFTER the “final” flag has been sent.

Is the STP PayEvent lodged with the ATO a return done through BAS agent portal if the business client's accounting software does not support it?.

The concept is that the ATO will offer an alternative portal to lodge STP if the business owner does not have payroll software.


How will the ATO know what amount of FBT to put on payment summaries?

System doesn’t change from current. Software will provide the ability to report the RFB amount either as a special reporting event or included in a PayEvent when you have the number ready to send. Some have stated they will provide the RFB amount as it progresses during the year – we believe this to be a rare exception to most systems.

Is it likely STP will extend later to smaller employers?

This would be a change to legislation. However, there is a small business paper pilot of the concept underway and we would suggest that it is just a matter of time. The minister has indicated they need to be assured of minimal impact and that there is benefit.

Will there be an option to revert back from STP if prior to compulsory dates?

No. Once you are in the system you remain in the system. Exceptions can be granted but not likely without extremely valid reasons.

Once you drop down from 20 employees will you still have to stay with STP?

Yes. Once you are in STP you will have to remain.

Will we BAS Agents be able to complete these tasks under out current scope of authority or will changes be required to our licence scope?

Providing certainty/advice and reporting about PAYG Withholding and SGC is a BAS Service. Running a payroll and providing pay slips etc. is not a BAS Service if is following a system and not crossing a line into BAS Services. The legal status of a submission of a PayEvent data to the ATO is yet to be finally determined. If you currently run payroll, you will be able to continue to run payroll. Every bookkeeper should certainly be positioning for their businesses that they know, understand and solve the Single Touch Payroll implementation for that business. Yes, I would be informing your client of your knowledge and expertise and solving the problem. If that means to include it in additional scope work or change to your engagement as a positioning and marketing tool I would be doing it.

I assume our Letters of Engagement will need to be carefully amended in relation to what we are now lodging on their behalf and what the client is required to lodge?

ICB recommend to update your letter of engagement to include the new process of STP.


This will make it very difficult for us to get around to all clients for their last pay event?

STP should not be any different to our current EOY process to all clients.

Does this mean that all employees will need to have a myGov account?

The concept is that the ATO will still publish the Payment Summary to the employee by another means.

In myGov you have to set up a new account and relink if you change your mobile number or forget a password. Will this be rectified, as some people have about 10 myGov accounts because they change their mobile or forget their password?

Recommend to inform myGov ATO of this issue. We will endeavour to investigate as well.

So more than 20 staff includes all casual staff? Even if they only work once a month?

Number of staff is a head count of staff in April 2017. There are discussions happening around the seasonal workers being exempted.

IF YTD reported, what happens if user made a mistake e.g. duplicated, and figures on the next pay and YTD are actually lower? Would the ATO be doing any checking throughout the year?

Yes, the ATO will be watching the data and the strategy is for soft touch enquiry. In the situation described simply provide the reason. A reduction is not a fatal item. Note: The final submission of YTD figures will be used by the ATO for the purpose of payment summaries and tax returns.

What will happen when a client goes in and deletes a payroll for an individual employee and re-enters it?

Each PayEvent of YTD values sent to the ATO will include this change. No issue as the next submission is the “source of truth”. Your most recent submission to the ATO will be current correct numbers.

What about quarterly clients who wait until the end of quarter for payroll to be processed?

These business owners may need to change their process and provide a PayEvent each pay run. Alternative arrangements and reporting concessions may be granted.

Sometimes the accountant doesn't know the director’s wages for the end of the year until later in following year. How will this affect the STP?

Yes, this has always been an issue for director’s fees/wages being paid after the end of the financial year. In theory, nothing changes and the back payments need to be accounted for in the correct period. It also depends if it is just being accrued or whether it is deemed paid, so tax needs to be taken out back in that relevant period. Amend the BAS and pay any interest.

What happens to unusual pay events – terminations?

Terminations will still be part of the YTD PayEvent however if an ETP is required this will still need to be supplied by the business owner. On the “Final” PayEvent there will be a field for ETP figures.


Will Final ATO pay Event include employees who have left employment during the tax year and will ATO send employees who have left business during tax year within 2 weeks of employee leaving?

Each YTD PayEvent sent to the ATO will include updated values for employees worked in that period. Therefore, an employee who has left will be part of the PayEvent YTD figures at time of termination and not updated again. The “Final” event at the end of the year will include these employees (proposed).

Employees of my clients won't accept the ATO giving them the info! They'll want me to give it to them.

STP currently is for employers with over 20 employees therefore the assumption has been made these employers are already computerised and the transition to STP should be relatively straight forward. We also believe it will take a couple of years before the culture changes away from the employer providing Payment Summaries or the equivalent.

If the ATO prefills W1 and W2 we'll still need to reconcile the wages? Or would that have been done before lodging with the ATO for PayEvents?

Reconciliation of wages is an important process of wages and BAS. This does not change under STP platform. The ATO will not be doing any “reconciliation” as such. The source of truth of the actual payroll is the employers records.

The ATO is assuming that employers will get it right, so how will we correct YTD on their behalf if only assist them at end of year?

As you will be finalising the “Final” PayEvent, this will correct the errors of the employer.

If the software providers will have it set up that all employers automatically report STP, they will always have to report this way. Will there be a way to stop this happening when the software providers turn this on?

Once you have entered STP you are in forever. We expect the software companies will solve the STP obligations for employers.

Does this mean, for example, that HR Block won't be doing personal tax returns?

All the normal avenues for doing your personal tax return will still be available. However, the ATO myGov tax returns will be prefilled if employees decide to use it.

Do you know if there are plans to include smaller employers in the future?

The system has not been imposed on small employers until it is up and running and the benefits can be realised, so no change at this stage. There is a small business evaluation pilot underway to inform the Minister of the benefits and burden of STP on small business.

Where are the information sheets on the ICB website?

Single Touch payroll has detailed resources at: http://www.icb.org.au/Resources/Payroll/Single-Touch-PayrollSimpler BAS resources: http://www.icb.org.au/Resources/GST--BAS/Simpler-BAS ICB Website – Resources/ Payroll/ Single Touch Payroll ICB Website – Resources/ GST & BAS/ Simpler BAS


Retail: The ATO delivery of solutions through their own technology and website, typically myGov or ATO Online. Wholesale: The system, typically using SBR, of the government interacting with Business Management Software (BMS) to allow submission of forms and provide information and verification back from the government. Onboarding: Sometimes termed commencement. The process of starting a new employee. myGov: The Australian Government’s web-based portal for individuals and increasingly business to interact with Government departments - myGov.gov.au SBR: Standard Business Reporting. Government system of standardising the list of terms and fields that are used when submitting data to Government. Includes technical specifications on delivery mechanisms. SG or SGC Superannuation Guarantee Contribution: The compulsory employer contribution to each employee’s superannuation. The SGC law doesn’t change. STP requires additional reporting of the accrual of SGC and then the payments. STP: Single Touch Payroll Substantial Employer: An employer with an employee of headcount of 20 or more people. Additional References ICB

§ http://www.icb.org.au/Resources/Payroll/Single-Touch-Payroll§ http://www.icb.org.au/Resources/Payroll/New-Employee-Checklist

ATO

§ https://www.ato.gov.au/About-ATO/About-us/In-detail/Strategic-direction/Simpler-reporting-with-Single-Touch-Payroll/

Legislation

§ https://www.legislation.gov.au/Details/C2016A00055 ATO - New Legislation Explanation Pages

§ https://www.ato.gov.au/general/new-legislation/in-detail/other-topics/single-touch-payroll/

Glossary and Additional References


ICB Resource: Commencing a Process Payroll

1. Is the employer aware of the relevant modern award for their business/industry; do you have a copy for reference?

2. If you are engaged to do so, define what are the entitlements, allowances, standard pay and any provisions beyond Fair Work National Employment Standards? If not, has the employer provided you with this information in writing?

3. Have all employees signed a TFN declaration form; where is it filed? 4. Have all employees been given a copy of the Fair Work Information Statement? 5. Has the employer chosen a MySuper product to be the default super fund for the business? 6. Have all employees signed a super choice form; where is it filed? 7. Have you assigned super fund and employee # to each card? 8. How are the superannuation payments paid, is there a better way? 9. What process is in place for employees to provide change of address, personal or annual

leave taken? 10. Is the client aware of the outstanding entitlements-- personal, annual, days in lieu, rostered

days off and long service leave? 11. Is the payroll electronically paid, if not why not? 12. Do the payslips hold enough information for the employee and does it conform to Fair Work

requirements? 13. Check monthly that payroll values equal profit and loss wages? 14. Check monthly/quarterly outstanding PAYGW is true, has the client paid the right value? 15. Check monthly/quarterly outstanding super is true, has the client paid the right value

ICB Resource: SuperStream http://www.icb.org.au/Resources/Payroll/SuperStream/Business-Information-Sheet-SuperStream SuperStream is a compulsory system of submitting Superannuation Payment information (standardised data) electronically. The information links the payment made by the employer to the employees account in the relevant superfund/s. It is the intention that SuperStream will make the whole superannuation system and employer meeting their obligations efficient, faster, more reliable and with less cost. How will SuperStream Benefit Employers? These changes have a range of potential benefits for employers, including:

§ The opportunity to use a single channel when dealing with super funds, regardless of how many funds your employees contribute to.

§ Less time spent dealing with employee data issues and fund queries. § Greater automation and reduced cost of processing contributions and payments. § More timely flow of information and money in meeting your superannuation obligations.

What are Your Options for Meeting SuperStream? Every business is different, so there’s no “one size fits all” approach to adopting SuperStream.

Appendix


Employers have various options; using software that conforms to SuperStream, or using a service provider that can meet SuperStream obligations on your behalf. Your options may include:

§ Upgrading your payroll software to an option that includes a clearing house service, § Using an outsourced payroll function or other service provider, § Using a commercial clearing house, § Using the free ATO Small Business Superannuation Clearing House (for employers whose

business has a turnover of less than $2 million or less than 20 employees), or § Your default fund may also have its own electronic channel. This fund can provide you with

details about how to comply with the SuperStream using their preferred facilities. Most employers will find it easiest to use a superannuation clearing house from within their payroll software to process SuperStream payments and send the required information. Important Information for Employers

§ SuperStream is mandatory for all employers who make superannuation guarantee payments or any other superannuation contributions for employees.

§ Employers must provide the minimum data to the super fund or clearing house electronically.

§ Ensure payments and data are linked by a unique payment reference number. § Ensure data and payments are sent on the same day. § Super funds are required to process contributions into the members account within 3 days. § Superannuation funds are obliged to contact employers within 5 days if data is missing or

invalid. § Employers must respond to any requests from a super fund for missing information or

queries relating to employee payments within 10 days. § Funds will have to refund contributions within 20 working days if they cannot be allocated to

an employee. § It remains your responsibility as the employer to confirm that super contributions have been

received, even if you use a clearing house or other service. § The Superannuation Guarantee (Administration) Act 1992 requires you to provide a

Standard Choice Form to your employees. This form will allow you to collect the required SuperStream related information from employees.

Additional Information Required Because the data is required to be submitted electronically, there are new fields of information that MUST be provided by you the employer to the superannuation fund or clearing house.

§ Unique superannuation identifier (USI) which identifies the fund § ABN and bank details for Self-Managed Super Funds § Electronic service address

Self-Managed Superfunds When you are paying into a Self-Managed Superfunds the following is required

§ For all Employees – The SMSF must provide ABN, Bank Details and an Electronic Service Address (ESA), the choice of service is found on the following link: ATO SMSF Service Providers

§ Related employees – e.g. a director, of paying into a related persons SMSF then SuperStream does NOT require the use of an Electronic Service Address. Ensure however the contributions are paid electronically. ATO example of related parties: Married couple run their own business and pays into their SMSF in the couple’s names.


SuperStream Does Not Mean it is a Tax Deduction You are still required to lodge and pay superannuation obligations by the quarterly or monthly due dates. However, the employer is not entitled to a tax deduction unless the payment is received by the respective superfunds by the due date. The employer must pay the clearing house in time for the payment to be received and allocated by the superfunds by the due date. Each clearing house has its own cut-off dates for receiving and distributing funds. Superannuation Guarantee Payment and Lodgement Dates Quarter Period of Payment Due Date 1 1 July – 30 September 28 October 2 1 October – 31 December 28 January 3 1 January – 31 March 28 April 4 1 April – 30 June 28 July

ICB Resource: PAYGW Obligations of an Employer http://www.icb.org.au/Resources/Payroll/PAYG-Withholding/ICB-Guide-to-PAYGW

Pay as you go (PAYG) withholding is a legal requirement by an employer to withhold amounts from payments to employees. The tax withheld is determined by the ATO tax scales published each year for weekly, fortnightly and monthly payments.

Who Withholds and Pays PAYG Withholding?

§ Any business who has employees § Any business where a contractor asks for voluntary PAYG withholding § Any business that has payments to other business where no ABN is quoted § Any business that pays dividends or royalties to non-residents

Obligations of PAYG Withholding Employers

§ Register to pay as you go (PAYG) withholding § Withhold amounts from wages and other payments § Lodge activity statements and make payments of PAYGW § Provide payment summaries to workers § Lodge Payment Summary Annual Report

When to Report PAYG Withholding

§ Small withholders - Withholds $25,000 or less per year, lodge quarterly (though you can choose to lodge monthly)

§ Medium withholders - Withholds $25,001 to $1 million per year, lodge monthly § Large withholders - Withholds $1 million per year or more, lodge twice a week

electronically. Your date for payment depends upon the day withholding took place, see table below


If you withhold an amount on: You must pay the withheld amount to the ATO by: Monday Following Monday Tuesday Following Tuesday Wednesday Second Thursday after that day Thursday Following Thursday Friday Following Thursday Saturday Second Monday after that day Sunday Second Monday after that day

Records to Keep for PAYG Withholding for Five Years

§ Wages records, including payment records § Voluntary agreements § Employment declarations - tax number and withholding declarations § Copy of payment summaries § Copy of employment termination payments (ETP) § Records of Personal Services Income (PSI) you have attributed § Statements by a supplier where no ABN was quoted, amounts withheld and annual report


Employee Details Name: __________________________________________________ D.O.B: ________________ Address: ______________________________________________________________________ ____________________________________________ Post Code: ________________________ Phone: ________________________________ Mobile: ________________________________ Email: ________________________________________________________________________ Do we have permission to email payslips and annual payment summary to the above email address? Yes / No Bank Account Details Account Name: _________________________________________________________________ Name of Bank: _________________________________________________________________ BSB Number: ___________________ Account Number: _______________________________ Superannuation Details As per Super Choice form provided. If Superannuation details are not received within two weeks of commencing employment, your employer superannuation contributions will be paid into our default company fund Care Super. Fair Work Information Statement A copy of the Fair Work Information Statement and National Employment Standards has been provided to you. Emergency Contact Details Emergency Contact: _____________________________________________________________ Relationship: ________________________________ Phone: ____________________________ I declare that this information is true and correct. Signed: _______________________________________ Date: __________________________ Office Use Only Commencement date: ____________________ Tax Form submitted: Yes / No: _______________ Pay Rate: __________________ First Review Date: __________________ FT / PT / Casual Super Choice Form received within 14 days of commencement: Yes / No TFN form lodged within 14 days of commencement: Yes / No http://www.icb.org.au/Resources/Payroll/New-Employee-Checklist

New Employee Checklist


Tasks Actions ü Obtain personal details of the employee Full name, address, contact phone and email,

emergency contact name and phone

Provide Superannuation Choice Form * ICB Guide to Employer Obligations Tax File Number Declaration Download from ATO. Once complete, forms

can be lodged with ATO via SBR or posted.

Provide Fair Work Information Statement Fair Work Information Statement Provide Award or Workplace Agreement information as appropriate.

ICB – Awards and Fair Work

Obtain information from employer regarding employment type and pay

Pay rate, entitlements, allowances, employment basis and classification

Provide Staff Policies and Procedures Handbook

ICB – Payroll Management Policy Template

Conduct Site Induction

* NOTE: most payroll software will allow you to print the Super Choice form from within the payroll section of the software.

Software Setup Actions ü

Set up employee in software Check Superannuation Fund details are valid

Add to superannuation clearing house if using outside of payroll software

Wages set up hourly or salary Check employment basis—full-time, part-time or casual

Entitlements See Fair Work Information statement Allowances For example, vehicle, laundry, meal, travel Workers Compensation Do you need to increase your level of cover? Payroll Tax If you are not already registered, will this new

employee’s wages trigger the threshold?

Time Billing and Jobs if relevant Add to payroll software if required

Expenses and Deductions For example, salary sacrifice, child support payments, union fees, extra PAYG.

Related References

§ ICB Guide to Employer Obligations § ICB Payroll Resources § ICB Guide to GovReports § ICB Guide to Workforce Guardian


The initial ATO discussion paper provided the following comments:

“By reporting and paying the PAYG withholding and SG for employees at the payroll cycle, businesses would be able to smooth out the cash flow spikes that previously existed. The increased transparency and frequency with which tax and super obligations are met would improve the risk credentials of business, and could be reflected in lower lending rates to business.

However, the increased frequency of payments will result in cash flow impacts, particularly on transition. Businesses typically would fall into one of the following categories when it comes to cash flow impact:

For businesses that already set aside their PAYG withholding and super obligations each pay cycle, the impacts should be relatively minor – however, this ‘cash reserve’ will be reduced because, for most businesses, payment will be required more frequently.For businesses that actively use the current delay between the payroll cycle and their tax and super obligation event to manage the cash flow of their business, this new process may create cash flow issues.

There is a small percentage of businesses in a net GST refund position, or entitled to fuel tax credits, that are also likely to see an impact on cash flow. Previously, these GST or fuel tax credits were used to offset the payment due for PAYG withholding – however, under Single Touch Payroll, businesses would be required to find the cash to pay the PAYG withholding to the ATO at the time of payroll and then receive a refund when they lodge their activity statement.”

More Frequent Payments We understand that some businesses do not manage their cash well and some businesses do incur a tax or SGC debt that increases in amount therefore requiring remedial action. The simplified cash flow logic and “smoothing” argument shows a fundamental lack of understanding of how a business operate. Business operates on the basis of their operational cash availability, being allocated to meet their multiple obligations. These obligations include the employees pay, the supplier payments, GST as well as the SGC and PAYGW amounts. Business considers all operational costs. For some small number of businesses, the more frequent payment to ATO or the superfunds will assist them to comply and suit their operational behaviour. For many compliant businesses that do manage their cash and meet payment cycles for PAYGW and SGC we see that STP imposes a huge economic impost on their existing business. If the business is paying the SGC earlier and the PAYGW earlier than they do not have the cash for a significant part of their trading cycle and hence will NOT be able to continue as much economic activity. If they have paid the PAYGW and SGC then they are not able to pay their suppliers and hence their ability to conduct business will be hindered.

The Cash Flow Debate


This economic impact should not be understated. We see that the paper is proposing that the timeline does not vary much and also arguing maybe a transition period to allow business to adjust. The fact remains that money will be taken out of the business economy earlier in a trading cycle than is currently the case and that this will have an impact. Be that now or in the full implementation post transition, cash will have been removed from the business cycle and provided to the government or into superannuation earlier. Item 1- The Original Current Scenario

We have added a blue column for the GST Cash and the Super and PAYGW cash replaced with the purpled columns Item 2 – Added in the Supplier Payments


Item 3 - Adds the STP Payments Each Month

We note that each of the Red indicates now “unfunded” previous payments to the suppliers. We also note that the week 5 PAYG/SGC payment remains as it relates to the prior year.

Item 4 – Delaying Supplier Payments

When we then allocate those “unfunded” suppliers into the new business cash flow, based on total outgoing as it was previously, we delay the “unfunded” suppliers until the timing that the PAYG/SGC was previously paid.

This has been presented as the unfunded supplier would have to wait until the cash was available. In reality for business they will now constantly juggle suppliers to be late.

The simple (delay payment) method results in:

§ Some suppliers delayed from week 1 to 15 and won’t be paid until week 18 § Some suppliers from weeks 16 to 19 until week 31 § Some suppliers from weeks 20 to 26 until week 36 § Some suppliers from weeks 27 to 44 until week 45 § Some suppliers from weeks 46 to 52 until week 6 of the following year


The juggling method (closer to the real world) would mean:

§ 1 unit of suppliers in payments from week 2 would be delayed until payments in week 6 § 2 units of payments from week 6 now paid in week 8 § 3 units of week 8 payments now paid in week 10 § 4 units of week 10 now paid in week 12 § 5 units of week 12 now paid in 14 § 6 from week 14 now paid in 16 § 8 from week 16 now paid in 18

The intention of this is to indicate the amount of extra administration and “red-tape” that a business must now manage if the fundamental framework of payments is altered on the basis of paying government and superfunds earlier.

§ Under STP the money is taken out of the business economy to pay super and tax earlier § This is a direct shift of operational business cash flow away from the business § We note that it is “only” a timing shift however the impact must be considered. § Businesses manage their SGC obligations and the PAYGW obligations in the cash flow

business cycle that exists. They plan to pay their debts as and when due. Earlier payment of ATO or Super means later payments to suppliers.

§ We propose that this is not a justified adjustment due to the actions of the non-compliant. § We propose that a better compliance program applicable to all based on existing

frameworks will result in better action towards the non-compliant. § STP increasing the obligations and cost on all compliant businesses is NOT justified.

Further to the above, changes to the frequency of payments may have consequences for other business practices, such as payment of invoices. A change of this nature for all employers is likely to increase market pressure within particular industries to reduce the number of days before invoices are paid.

§ This economic impact should not be understated.


1. ATO Concept Presentations in 2014

6

Single Touch Payroll is a concept that leverages the natural payroll cycles to fulfil all “employer” reporting and payment obligations to various government agencies and other intermediaries “at the touch of a single button”.

Business would follow their normal business processes in completing their payroll. The payroll process could allow businesses to simultaneously fulfil their reporting and payment obligations (for example paying staff and issuing payslips, reporting and paying earnings and taxes to government and reporting superannuation electronically).

The concept could also provide a foundation for: • improving the annual individual income tax return process as information will be available on

an ongoing basis;• the provision of a single universal citizen account (enabling the balancing of payments or

liabilities across government agencies); and• eliminating the need for income reporting by individuals to other agencies (for example in

welfare, student or child support areas)

Executive Summary

History of the Journey


7

SingleTouchPayroll– Commencement(currentvs future)

Commencement of new

employee

Commencement

TFN Declaration

Employer sends ATO

copy due within 14

days

Employer Files

Form

Employer Files

Payer Copy

Employer Files

Forms

Information

entered into payroll

package,

including:

Employee details,

TFN Declaration

and Super Choice

data

• TFN Declarations outbound – 10M

• TFN Declarations inbound – 3.9M

Only includes paper and MIPs volumes

Commencement

Information entered into

payroll package, including:

• Employee details

• TFN Declaration and

• Super Choice data

ELIMINATED:

• TFN Declarations outbound – 10M

• TFN Declarations inbound – 3.9M

Superannuation

Choice Form

TFN Declaration

Employee Details and

Bank Account Form

Commencement of new

employee

Future

Current

Validated information sent to

• Employer

• Superfund

• ATO

• Other relevant agencies

Employee completes one

commencement form ONLINE with

Government.

8

What if employee notifies…‘started a new job’?

No TFN Declaration, No

Super Choice form


9

SingleTouchPayroll– Payment&ReportingObligations(currentvs future)

10

Current

$-

$5,000.00

$10,000.00

$15,000.00

$20,000.00

$25,000.00

$30,000.00

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51

Week (Fiscal Year 2011-12)

Cas

h Fl

ows

Out Super

PAYGWSalary/WagesTotal incl. GST & PAYGITotal Employee Costs

Natural Systems

$-

$5,000.00

$10,000.00

$15,000.00

$20,000.00

$25,000.00

$30,000.00

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51

Week (Fiscal Year 2011-12)

Cas

h Fl

ows

Out Super

PAYGWSalary/WagesTotal incl. GST & PAYGITotal Employee Costs

Single Touch Payroll – Cash Flow (current vs future)

Future

Current


SingleTouchPayroll– Benefits(currentvs future)

Businessû Additional administrative burden, not aligned to

natural systemsû Debts grow as the “spiking” payment events impact

cash flowû Long cycle times and the disconnects between

natural (payroll) events, reporting events and payment events enable Phoenix behaviour to flourish – thus compromising the “level playing field”

ATOû Processing and exception workloads due to paper and

magnetic mediaû Increased “debt” & “compliance” workloadsû Reduced opportunity to “pre-fill” due to lag between

payment summary lodgment and ITR lodgment (only 72% of returns pre-filled)

û Almost nil access to real time data or real time trends

Australia and for the broader communityû Compromised tax revenues and compromised

superannuationû Inefficiencies in the tax and super systemsû Inefficient data matching between agenciesû Significant negative environmental impact (over 1000

tons of outbound paper as well as delivery, storage and processing impacts)

Future

Current

13

ATOü Improved administration of the tax and superannuation

systems, due to:ü Reduced operational costs (eg associated with capture,

paper processing, phone calls and complaints)ü Reduced Debt and Compliance workloadsü Eliminates need for the Members Contribution Statement

(MCS)ü Reduction in Phoenix behaviour as payment and

reporting lag times are reducedü Creates opportunities for interactive withholding rate

changesü Allows real time data matching between agencies (eg

Centrelink & CSA)ü Increased capacity for operational analyticsü Increased prefill as information is available on 1 July each

year

Australia and the broader communityü Protects tax and super revenues for the community and

Australiaü Increased efficiency in the administration of the tax and

super systemsü Increased transparency and ownership of tax and super

systems by individuals (PAYGW and SPR are embedded into their ‘pay day’ events’)

ü Supports business migration to ecommerce/ data standards (eg SBR)

ü Improved data matching between agencies (eg ASIC, DISSR, CSA & Centrelink)

ü Reduction in the ATO environmental footprintü Real time payments by the RBA

Points for consideration§ Need to consider an incentive that offsets the $$ interest

on cash flow§ Legislative & policy considerations§ The ATO will need to work with software providers and

the community to design a seamless experience

Businessü Reduced administrative burden for business as:

üAll payroll obligations and liabilities are actioned at time of payroll

üReduced reporting obligations and payment eventsü Improved cash flow managementü Increased first point resolution

ü Immediate reduction in Phoenix behaviour (ie level playing field)

ü Decreases complexity of reporting super and projected super payment dates on payslips

û Transition needs to be managed to minimise cash flow impact

û Requires employers to pay via electronically enabled payroll software

û Some employers will see this as a reduction in their control over their business (even though they are using PAYG or SPR funds)

Individualsü Clients will have confidence that super entitlements

are up to dateü More timely access to prefilled information

14

SingleTouchPayroll– Firstroundfeedbackfrom2013

Practitioner FeedbackProfessional association forumsü Very supportive of STP conceptü Significant “red tape” reduction opportunitiesü Overwhelming agreement that it would reduce

businesses getting into “irrecoverable” debtü Believed it would help “level the playing field”ü Believed that ATO should be much firmer in driving

the adoption of accounting/business software via “mandatory” digital requirements

ü Agreed that “carve-out” provisions should only be for the most extreme circumstances

• Need to cater for “transitional” cash flow impact for small businesses

û Recognised that some practitioners and businesses would be resistant to “mandatory” digital requirements

Suburban practitioners• Mixed feedback…. generally reflected their digital

literacy and business modelsü Some only dealt with businesses that used

accounting software. Supported STP. ü Small number in “cloud”. Supported STP.ü Most agreed that STP would require mandatory

implementation with support.û Some did not know existing digital functions already

available in softwareû Some recommended clients “not” use any software

(ie. agent was glorified bookkeeper)û Some saw software as a threat to their business

model

Software Developer Feedbackü Absolute support for STP conceptü Many already aware of mandatory digital

developments & the rollout of UK RTIü Some already engaged in developing software product

for the UK RTI marketü Recognised that STP offered significant opportunities

to streamline obligationsü Agree with the direction towards a fully integrated

digital reporting/payment environmentü Recognised that pricing and product range will need to

be more accessible for businesses and believed this would happen as a result of a broader demand base (as per UK …post RTI)

ü Cloud solutions & subscription models already reducing costs & complexity of software offers

• Prefer 18mths to 24mths lead in time to allow development of product

• Want strong engagement and input on design and functionality

• Want learnings from UK RTI to be recognised in Australia so as to improve the product development process

û Developers will NOT invest in building compatible software unless there is a clear roadmap which includes publicly announced mandatory timelines

û Some developers believe that the ATO has compromised them by “shifting the goal posts” after making firm timeline commitments in the past (thus jeopardising the investments made by developers)

Small Business Feedbackü All used digital technology (eg. web, internet

banking, social media, ordering products)• All complained of “red tape”, including TFN Dec,

Super amounts choice (none actively offered it), PAYGW, Super, PAYGW Summaries etc

• Most used an electronic option to calculate PAYGW for payroll (eg. ATO PAYGW calculator & accounting software)

• Most used old unlicensed versions of software because it had been too hard to upgrade, update and maintain software

• All manually managed payroll and other obligations (eg. manual internet banking, paper payment summaries etc)

ü All interested in streamlining payroll, but were only reassured after they worked throughüscreen shots showing usabilityüsecurity features (ie. compared to internet

banking)ücosts of software versus savings

ü All agreed that STP would flatten cash flows and reduce quarterly cash flow “stress”

ü Agreed that once implemented, STP was easier and more seamless than current processes (“it fulfilled obligations without me having to do anything”)

ü Agreed that it would “level the playing field” (non-compliers are a significant risk to their competitiveness)

û Worried about the transition (ie. carryover of existing obligations whilst implementing STP)

û Wanted plenty of notice and support


2. ICB News item January 2015 following the Minister’s Media Release: Single Touch Payroll What is it? On 28/12/14, the Minister for Small Business and the Assistant Treasurer announced that the Government will cut red tape for employers by simplifying tax and superannuation reporting obligations through Single Touch Payroll (STP).

§ Under STP, employers will use business management software to report (and potentially pay) PAYGW and super guarantee at the same time as wages are paid to employees.

§ This will eliminate the need for employers to report employee-related PAYGW in their activity statements throughout the year and employee payment summaries at the end of the year.

§ In addition, the Government will streamline Tax File Number declarations and Super Choice forms by providing digital services to simplify the process of bringing on new employees.

§ STP builds on the Government’s investment in Standard Business Reporting and relies on software developers to provide software solutions that meet the needs of employers.

STP will be available from July 2016 and transition arrangements will be the subject of consultation with the business community early in 2015. Consultation will focus on:

§ The phasing of the start date for different sized employers to report via Single Touch Payroll § The arrangements to support the move to Single Touch Payroll. § The potential for employers to pay PAYGW and the Superannuation Guarantee at the same

time employees are paid their salary and wages and what support would be required for this

ATO aims in part

§ A comprehensive understanding of how users want or need to use current products and processes and how this will change as a result of the new/changed products and processes that STP will deliver

§ STP champions that will work with peers and clients to build understanding and support during transition and beyond

§ To jointly develop a high-level plan, including timeframes, to ensure we deliver on the Governments agenda (and the critical date of July 2016)

ATO positioning paper Single Touch Payroll is a concept that leverages the natural payroll cycles to fulfil all “employer” reporting and payment obligations to various government agencies and other intermediaries “at the touch of a single button”. Business would follow their normal business processes in completing their payroll. The payroll process could allow businesses to simultaneously fulfil their reporting and payment obligations (for example paying staff and issuing payslips, reporting and paying earnings and taxes to government and reporting superannuation electronically). The concept could also provide a foundation for:

§ improving the annual individual income tax return process as information will be available on an ongoing basis;

§ the provision of a single universal citizen account (enabling the balancing of payments or liabilities across government agencies); and

§ eliminating the need for income reporting by individuals to other agencies (for example in welfare, student or child support areas)


3. Minster’s Media Releases Cutting red tape for employers through Single Touch Payroll – 28th December 2014 Joint media release with The Hon Bruce Billson - Minister for Small Business

The Minister for Small Business, Bruce Billson, and the Assistant Treasurer, Josh Frydenberg, today announced that the Government will cut red tape for employers by simplifying tax and superannuation reporting obligations through Single Touch Payroll.

Under Single Touch Payroll, employers’ accounting software will automatically report payroll information to the Australian Taxation Office (ATO) when employees are paid.

This will eliminate the need for employers to report employee-related Pay As You Go Withholding (PAYGW) in their activity statements throughout the year and employee payment summaries at the end of the year.

In addition, the Government will streamline Tax File Number declarations and Super Choice forms by providing digital services to simplify the process of bringing on new employees.

Single Touch Payroll builds on the Government’s investment in Standard Business Reporting and utilises the innovation of software developers to provide accounting software solutions that meet the needs of employers.

Single Touch Payroll will be available from July 2016 and transition arrangements will be the subject of consultation with the business community early in 2015. The ATO and the Treasury will consult with the community on the phasing of the start date for different sized employers and the arrangements to support the move to Single Touch Payroll. This will include how the new arrangements will build on the SuperStream changes currently being implemented.

In addition, consultation will examine the potential for employers to remit PAYGW and the Superannuation Guarantee at the same time employees are paid their salary and wages, and what support businesses may require to enable such a transformation in payments to government and superannuation funds.

The Government is committed to working with business and this is another significant policy that will reduce red tape costs on an ongoing basis.

Extracted from: http://jaf.ministers.treasury.gov.au/media-release/001-2014/


Streamlining business reporting with a single touch payroll – 21 December 2015

The Minister for Small Business and Assistant Treasurer, the Hon Kelly O’Dwyer MP, today announced business reporting of tax and superannuation will be simplified with the implementation of Single Touch Payroll (STP).

“Employers currently manually report Pay As You Go (PAYG) withholdings to the ATO,” Minister O’Dwyer said. “Under the new STP this information will be automatically reported to the ATO through Standard Business Reporting (SBR) software.

“Reporting of superannuation contributions will also be automatically sent to the ATO when payments are made to super funds.”

“Employers will also have the option to pay their PAYG withholding at the same time they pay their staff.

“The Turnbull Government is also introducing streamlined processes for individuals commencing employment. Individuals will have the option of completing their Tax File Number (TFN) declaration and Superannuation Standard Choice forms using myGov or through their employer’s business management software.

“The ATO will be conducting a pilot in the first half of 2017 to demonstrate the deregulation benefits for businesses, with a focus on small businesses, to make sure we get it right.

“From 1 July 2017, all businesses will be able to commence STP reporting, with the option to make voluntary payments. In addition, the ATO will transition employers with 20 or more employees to STP. From 1 July 2018, employers with 20 or more employees will be required to use STP enabled software for reporting to the ATO.

“The Government will make a decision on timing for rolling out STP reporting for employers with less than 20 employees after the pilot is completed.

“To assist with the transition the Government will provide businesses, with a turnover of less than $2 million, a $100 non-refundable tax offset for SBR enabled software,” Minister O’Dwyer said.

This offset will apply from 1 July 2017 and will be available for software purchases or subscriptions made in the 2017-18 financial year.

Extracted from: http://kmo.ministers.treasury.gov.au/media-release/042-2015/


Institute of Certified Bookkeepers represents Members, Bookkeepers and Business including the following Single Touch Payroll discussions:

§ ATO Single Touch Payroll Advisory group (policy and governance) § Treasury Legislation consultations § ATO STP Design Working Groups (detailed design) § ATO STP Change Management Readiness consultations (business implementation

preparation) ICB is also involved in associated consultations at the following:

§ ATO Australian Tax Practitioners Advisory Group § BAS Agents Association Group § ABR Board § ATO Working with our Partners Program Board § ATO Future of the Tax Profession working groups § Digital Business Council § COSBOA § ABSIA

ATO Consultation Framework

Executive Director Email Matthew Addison [email protected]

Company Directors John Birse [email protected] Amanda Linton [email protected] James Carter Garry Carter

General Manager Rick Van Dyk [email protected]

Events and Network Meetings Coordinator Carmel Wright [email protected]

Management Support Simone Beatty [email protected] Emily Wood [email protected]

Member Services Jan Tacey [email protected] Toni Ortika [email protected] Jessica Mierke [email protected]

Website Publisher Helen Harrison [email protected]

Technical Resources and Support Chris McComb [email protected] Jo Voight [email protected] Pauline Walton [email protected] Deb Thompson [email protected] Sarah Priestley-Hill [email protected] Gabriela Ornig [email protected] Wendy Hughes [email protected] Leanne Berry [email protected]

Enquiries Phone: 1300 85 61 81 Fax: 1300 85 73 93 Email: [email protected] Web: www.icb.org.au

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