First Supplementary Annual GST Return

August 2025 first due date for the Supplementary Annual GST Return (SAGR).

Supplementary Annual GST Return

For December year-end large market taxpayers, this month (21 August) sees the due date for the very first Supplementary Annual GST Return (SAGR).

The SAGR is a new development in the Goods and Services Tax (GST) reporting framework that will impact Top 100 and Top 1,000 taxpayers. The SAGR aims to provide the Australian Taxation Office (ATO) with comprehensive data to enable the identification of emerging GST risks while ensuring the accuracy of GST reporting and adherence to governance standards.

It requires taxpayers to undertake an annual self-assessment and make disclosures relating to the following key areas:

• ATO recommendations, areas of low assurance or red flags from prior GST assurance reviews;
• GST governance frameworks;
• The alignment between GST and financial statements (GST Analytical Tool or GAT);
• Any materially uncertain GST positions; and
• Material GST reporting errors or credits claimed in a later BAS.

GST Analytical Tool

With the SAGR now effectively legislating the GAT, it means that what started as an internal ATO case selection tool is now here to stay and very likely to apply to more taxpayers

Approaching the GAT usually begins with the audited financial statements; however, the majority of the work focuses on the detailed trial balance and the application of key adjustment areas, including GST grouping, non-GST transactions (such as exports and salaries), and reconciling differences between accounting methods and GST invoicing.

While the GAT can present challenges, particularly for large corporate groups with mismatched economic and GST groups, the process can offer significant insights into a GST compliance framework. The first completion is always the hardest, but it becomes easier with practice. As you deepen your understanding of the differences between your Profit and Loss statement (P&L) and Business Activity Statement (BAS), you can identify valuable adjustments. Supporting these adjustments with solid evidence, such as general ledger balances, is essential to keep the ATO happy.

Due dates

The due date for the SAGR will depend on the taxpayer’s year-end and is generally at least seven months after the financial year-end.

Importantly, the SAGR does not replace any other GST returns that are required to be lodged, and penalties can apply if it is not lodged on time, or if false or misleading statements (including omissions) are made. In reporting terms, it carries the same weight as the Business Activity Statement.

Although the SAGR introduces an additional compliance requirement, it also serves as an opportunity for taxpayers to engage with the ATO concerning GST issues proactively. By integrating these new reporting obligations into their existing GST control frameworks, taxpayers can not only facilitate the annual preparation of their SAGR but also encourage a more tailored approach from the ATO concerning GST Justified Trust.