STP Design Working Group
Presenter: Ian Colhoun, Director
Single Touch Payroll
Thursday, 1 December 2016
Email: [email protected]
Outcomes from Deep Dive– Super Reporting
Core Principles
•
•
•
•
•
•
Employer must report on or before date of payment to trustee
There is no change to payment or SG obligations
We are reusing SuperStream –reuse an existing process to assist in
managing cost
Allocation and payment information will provide early visibility to ATO of
whether an employer is meeting their SG obligations for each
employee
This produces assurance employer has met SG obligations, but is not
going to replace SGC notifications, as it cannot be fully reconciled even
when the ATO receives MCS reporting data (MCS data does not
always accurately identify the employer).
We should capture data where it is about to be processed to ensure it
includes all Superstream data and corrections made by intermediary.
UNCLASSIFIED – STP Design Working Group – 1st December 2016
2
Outcomes from Deep Dive– Super Reporting
Issues/Questions Identified
•
•
•
•
•
•
Does there need to be a declaration in the message to support sending
by the intermediary? I.e. employer stating all data is true and correct
ATO will support data direct from employer solutions where they can
provide data and connect to SBR2. If we capture earlier in the chain
data is unlikely to support PRN/payment date.
Can employer send all data in the CTR? – privacy issue for ATO to
consider
Who pays for sending costs?
Intermediaries will need a legal/commercial agreement with the
employer to support sending of information, this will be a change to
existing agreements
Do we need a Flag to fund by employer asking them to notify ATO of
positive processing of contribution?
UNCLASSIFIED – STP Design Working Group – 1st December 2016
3
Outcomes from Deep Dive – Super Reporting
Issues/Questions Identified (cont.)
Opt out or opt in (legal privacy issue) – can aggregators have an opt
out model for sending STP SPR data?
Authorisation model for ATO receipt of data (legal privacy issue)
Quality of data – is there a response to the data provided to the ATO
• what validation occurs in the channel?
• What does ATO reject?
What data is in XML file – what does Channel B file look like
• Is this the same as CTR, how do we understand mandatory versus
optional ta requirements
How do we differentiate duplicates vs Resends in the design?
What does implementation look like?
UNCLASSIFIED – STP Design Working Group – 1st December 2016
4
Outcomes from Deep Dive– Super Reporting
ATO Position
•
•
•
an employer will need to give a declaration that the information
provided was true and correct
an employer will need to authorise the sender to provide the
information to the Commissioner
Both of those declarations could be provided as part of the
contractual "sign on" between the employer and their service
provider
The agent would then need to provide a declaration that:
• they have the required declaration from the employer
• that the report had been prepared in accordance with the employers
data
• that the agent has been authorised to submit the information to the
Commissioner
UNCLASSIFIED – STP Design Working Group – 1st December 2016
5
Outcomes from Deep Dive– Super Reporting
ATO Position
We will incorporate these requirements into the terms and conditions of
use of the service. These would state that the declarations and
authorisations are required pre-conditions before an agent or
intermediary could submit data through the service to the
Commissioner.
We consider this would therefore preclude both:
• an “opt out” process for an agent/supplier,
• an agent sending data for a non STP employer, as no authorisation
would be in place.
UNCLASSIFIED – STP Design Working Group – 1st December 2016
6
Outcomes from Deep Dive– Super Reporting
ATO Position
No separate flag will be required in the Superstream CTR to confirm
that data should be provided to the ATO, as this will be required to be
included in the agreement with the employer.
Subject to the sending solution providing all necessary data in the
correct format and channel, the ATO will not limit who can send the
data to the ATO. This will support employer direct to SBR2 lodgement
in the same manner as payroll data.
Whilst the reporting is an employer obligation, that does not prevent a
trustee or third party supporting an employer as part of a service
offering, as long as they are authorised to do so by the employer
UNCLASSIFIED – STP Design Working Group – 1st December 2016
7
Application of ATO position to Sending Solutions
Channel B Impacts
UNCLASSIFIED – STP Design Working Group – 1st December 2016
8
Standard High Level
Contribution Data Flow
Employer
Trustee A
Service
Provider
Payroll
Gateway
SuperStream
Transaction
Network
Agreed Principle
Gateway
Service
Provider
Trustee B
“CTR data should be sent to the ATO where
the Superstream Obligation is met”
Data Sent to ATO
ATO
UNCLASSIFIED – STP Design Working Group – 1st December 2016
9
Standard High Level
Contribution Data Flow
Employer Direct
Employer
Trustee A
Service
Provider
Payroll
Gateway
SuperStream
Transaction
Network
Agreed Principle
Gateway
Service
Provider
Trustee B
“CTR data should be sent to the ATO where
the Superstream Obligation is met”
Data Sent to ATO
ATO
UNCLASSIFIED – STP Design Working Group – 1st December 2016
10
UNCLASSIFIED – STP Design Working Group – 1st December 2016
11
Standard High Level Contribution
Data Flow
Channel B – Receiving Solution
Employer
Trustee A
Service
Provider
Payroll
Gateway
SuperStream
Transaction
Network
Agreed Principle
Gateway
Service
Provider
Trustee B
“CTR data should be sent to the ATO where
the Superstream Obligation is met”
Data Sent to ATO
ATO
UNCLASSIFIED – STP Design Working Group – 1st December 2016
12
Agenda Item 3
Afternoon Tea Break
UNCLASSIFIED – STP Design Working Group – 1st December 2016
13
Agenda Item 4
Superannuation Reporting Extract
UNCLASSIFIED – STP Design Working Group – 1st December 2016
14
Outcomes from Deep Dive– Super Reporting
ATO Position
Our starting position is that we will need to support a copy of the
SuperStream Contribution Transaction Message (CTR) in both XML
and XBRL format.
Validation on the file would start with the existing validation applied to
the SuperStream CTR with the following caveat:
The ATO is supporting the collection of the Superstream CTR to
reduce the cost of implementation by re-using the existing file content
generated to a trustee. Where this data extends beyond the
mandatory data required to confirm payment of SG amounts it will only
be optional. The ATO will still use the optional data to support
interactions with the employee/member, for example with nonconcessional contributions.
UNCLASSIFIED – STP Design Working Group – 1st December 2016
15
Outcomes from Deep Dive– Super Reporting
ATO Position
We are currently reviewing the mandatory data required to support SG
payment amounts. This could include any information that is required
to support the correct amount of SG being paid:
• Employer details
• Fund details
• Employee/member details
• Employer related contribution amounts, including salary sacrifice
amounts
• Information which supports allocation of the amounts to the correct
period
UNCLASSIFIED – STP Design Working Group – 1st December 2016
16
Outcomes from Deep Dive– Super Reporting
ATO Position
Review outline of Superannuation Taxonomy
UNCLASSIFIED – STP Design Working Group – 1st December 2016
17
Outcomes from Deep Dive– Super Reporting
ATO Position
A core question still under consideration is whether the ATO will need
to support both XBRL and XML formats.
We are seeking industry feedback on whether any sending solutions
are expecting to generate XBRL files to the Commissioner.
UNCLASSIFIED – STP Design Working Group – 1st December 2016
18
Agenda Item 5
Superannuation Design Issues
UNCLASSIFIED – STP Design Working Group – 1st December 2016
19
Questions?