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Next 5000 Assurance Review Program

Understanding ATO’s Next 5000 Program and Private Wealth Audits

The Next 5000 Program is an initiative by the Australian Taxation Office (ATO) targeting Australia’s privately owned groups and wealthy individuals with net wealth between $50 million and $500 million. These taxpayers are subject to enhanced compliance activities, including tailored reviews, streamlined assurance programs, and full audits where necessary. The program follows the success of the ATO’s Top 500 Program aimed at the largest private groups.
The ATO’s Next 5000 reviews focus on ensuring correct reporting of income tax, capital gains tax (CGT), GST, and the appropriate use of trust and company structures. Private groups often face audits triggered by complex business structures, significant inter-entity transactions, large CGT events, international dealings, and succession planning arrangements. The ATO uses sophisticated data analytics and information sharing with domestic and international regulators to identify risks within private wealth groups.

Responding to a Next 5000 audit can be resource-intensive, often requiring extensive input from accountants, tax lawyers, and corporate advisors to document governance, financial reporting, and tax positions. Tax audit insurance from AuditCover can help cover the significant professional fees incurred during these reviews, protecting your business group and personal assets. Below, we answer the most common questions about the ATO’s Next 5000 audits and how audit insurance can assist.

FAQs

The Next 5000 Assurance Review is a targeted compliance program run by the Australian Taxation Office (ATO). It applies to privately owned groups with net wealth exceeding $50 million. The program is part of the ATO’s “Justified Trust” initiative, which aims to confirm that Australia’s wealthiest private groups are paying the right amount of tax.

While it is not a formal audit, the process is thorough and can involve months of document gathering, interviews, and follow-up reviews. A review may escalate into a full audit if the ATO is not satisfied with the group’s tax governance or supporting documentation.
The review focuses on high-risk tax areas and the strength of the group’s governance. Areas typically covered include:
  • Income tax positions, especially around large deductions or deferrals
  • Capital gains and business restructures
  • Trust distributions and Division 7A compliance
  • Related-party transactions and offshore dealings
  • Tax governance frameworks and documentation
The ATO will request internal documentation, legal advice relied upon, and records supporting the group’s interpretation of complex tax matters.
Selection is based on wealth thresholds, corporate group structures, and risk profiling by the ATO. Private groups controlling multiple entities, family trusts, SMSFs, and companies—particularly those with offshore investments or large inter-entity loans—are more likely to be included.

Groups with significant one-off transactions, such as the sale of a business or restructuring of assets, are also common targets.
Even if no errors are found, these reviews are resource-intensive. Groups may face:
  • Significant costs in gathering and presenting documentation
  • Reputational exposure if cooperation or transparency is questioned
  • Follow-up queries that extend the duration of the review
  • Escalation to a full audit if the ATO is not satisfied with responses
  • Potential reassessments, penalties, or interest where tax positions are disputed

These reviews typically require input from accountants, tax lawyers, in-house finance teams, and sometimes external advisors. Managing the review is costly and time-consuming—especially when specialist advice is needed.


AuditCover’s tax audit insurance covers:

  • Accountants’ time preparing documentation and responses
  • Tax agent and legal fees
  • Time spent by internal finance teams billed externally
  • Correspondence and negotiations with the ATO

This ensures the group can respond comprehensively without delaying key deliverables or absorbing large, unplanned costs.

AuditCover is trusted by leading accounting and law firms to deliver tax audit insurance solutions for private groups. We offer:

  • Tailored policies that include high-net-worth and corporate group reviews
  • Coverage for all major ATO and state-based audit types
  • Support for accountants and private wealth advisers
  • Fast claims handling and dedicated client service
If your group is likely to be reviewed—or has already been contacted by the ATO—get a quote. If you’re a private client adviser or accountant, join the AuditCover Partner Program to provide clients with the confidence to navigate complex ATO scrutiny.

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This insurance is issued by Auditcover Australia Pty Ltd (ABN 63 638 872 634, AFSL 535509) on behalf of the insurer HDI Global Specialty SE (ABN 58 129 395 544, AFSL 458776).

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