The ATO’s Top 500 and Next 5000 programs started out focused on Australia’s wealthiest private groups. In 2026 those programs do more than keep large groups honest — they set expectations the ATO now applies across the private‑wealth sector, including small and medium enterprises.
If you run a family business, trade through multiple entities, use trusts, or are planning a sale or restructure, the themes coming out of these programs are a useful playbook. They show what the ATO regards as “high risk”, what it will ask for in an engagement, and where you can remove risk before a review starts.
What SMEs should care about the Top 500 & Next 5000 programs
- Standards flow down: What the ATO enforces for the Top 500 tends to become standard practice for everyone.
- Same expectations, smaller scale: The emphasis on documentation, governance and consistency now applies to smaller groups — not just large private families.
- Early fixes save money: Addressing governance and record-keeping problems before a review prevents costly adjustments and penalties later.
The ATO’s emerging focus areas, and how they affect you
1. Stronger tax governance is expected
- What the ATO wants: documented tax governance procedures, clear decision‑making records, up‑to‑date trust resolutions, and timely lodgements and payments.
- SME impact: Even simple governance gaps can trigger follow‑ups or voluntary disclosures. In Top 500 reviews, governance failures were the root cause of most voluntary disclosures — the same issues turn up in small groups.
2. Everyday compliance mistakes are red flags
- Common mistakes: undocumented shareholder/related‑party loans, missed Division 7A repayments, GST errors, missed FBT, wrong CGT treatment and trust distribution/UPE issues.
- SME impact: These are easy for the ATO to spot and expensive to fix. Fix the basics first — correct paperwork beats firefighting later.
3. Major transactions trigger scrutiny
- Transactions watched closely: business sales, restructures, refinancing, property purchases/transfers and internal restructures.
- SME impact: Expect questions on valuations, tax treatment, CGT reporting and GST classification when you transact.
4. GST reviews are becoming routine
- What the ATO looks at: GST‑free vs input‑taxed supplies, related‑party recharges, export treatments, construction/property transactions and input tax credit substantiation.
- SME impact: The ATO’s 12‑month detailed GST approach used in larger reviews is filtering down — accurate GST treatment and strong supporting records are essential.
5. Property and construction remain a hotspot
- Key concerns: property development within groups, SMSF participation in projects, trading stock vs capital asset classification and profit allocation across entities.
- SME impact: If you’re in property or construction, the ATO expects commercial terms, arm’s‑length pricing and defensible documentation.
What ATO compliance measures mean for your business
If your SME:
- uses a trust
- pays directors/shareholders instead of wages
- owns property
- has related‑party loans
- has cross‑border dealings
- is planning a restructure, sale or refinance
…these ATO focus areas apply directly. Strong governance and documentation now will put you in a better position if the ATO reviews your affairs.
Practical steps to reduce risk
ATO reviews are increasingly focused on everyday SME tax settings, especially where trusts, related‑party arrangements or transactions are involved. Taking a few simple steps now can materially reduce risk, strengthen your position in any review, and ensure your tax affairs are defensible and well‑documented.
- Tax governance: Simple, tailored approval and record‑keeping processes .
- Related‑party compliance: Up‑to‑date loan agreements, repayments, Division 7A and UPE records.
- GST accuracy: Correct supply classification, related‑party charges and input tax credits.
- Trust hygiene: Timely resolutions, clear distribution records and trustee minutes.
- Transaction readiness: Document valuations, commercial terms and tax analysis early.
- Pre‑review check: Identify and fix likely ATO queries upfront.
How BlueRock can help
We focus on practical, commercial solutions, not unnecessary complexity. We help thousands of SMEs with:
- Tax governance frameworks for SMEs
- Division 7A, trusts & UPE compliance
- ATO review readiness & audit support
- GST & FBT risk reviews
- Support for major transactions
- Ongoing advisory & strategic planning
Ready to strengthen your tax position? If you want peace of mind, are planning a transaction , or need help preparing for ATO engagement, we can help you reduce risk and build a stronger tax governance foundation. Get in touch via the form below and we’ll talk through a practical plan tailored to your business.
