Participating Advisor: pioneering a stronger, transparent tax system

By Viola Trnski, Haidee Watkin & Jeanne Du Buisson

Inland Revenue’s investigation powers have received boosts in Budget 2024 and 2025, with millions in extra funding each year being specifically assigned to increase audit and investigation activities. And it is working, with $880.8 million of additional tax being assessed from audits in just nine months from 1 July 2024 to 31 Mach 2025 (up from $460 million in 2024). It’s fair to say Inland Revenue “are back” in the game and are looking for returns on investment for the Government by materially increasing audit activity. Many taxpayers are unlikely to have gone through an audit so it’s a bit of an unknown quantity, with a general perception that they can be very time consuming and are best avoided if possible. That’s where Inland Revenue’s Participating Advisor programme can step in to provide taxpayers with an alternative option.

Participating Advisor

Inland Revenue recently announced the launch of the Participating Advisor programme. This is an initiative to enhance tax governance and compliance by giving taxpayers the option to have a reviews of certain tax types (GST, FBT and Payroll) undertaken by an approved tax advisor rather than Inland Revenue. These can be proactively undertaken by taxpayers as part of an organisation’s tax governance framework, or undertaken in response to Inland Revenue attention.

Deloitte is proud to be an approved Participating Advisor for GST, FBT and Payroll reviews.

Participating Advisor is a pioneering example of how tax advisors and tax authorities can work together to promote tax governance and compliance.  This new framework overlays Deloitte’s traditional GST, PAYE, FBT and data analytics review products, and provides taxpayers with an additional layer of assurance that Inland Revenue will not undertake further review/audit if Deloitte’s review aligns with Inland Revenue’s scope and timeframe. Feedback from organisations who have already had a Participating Advisor review (PAR) has been that the PAR has been successful in the context of Inland Revenue review and audits, as part of regular tax governance programmes and they have also been useful in the context of due diligence reviews (including vendor due diligence).

How do I initiate a Participating Advisor review?

A PAR can be initiated in two ways:

1. As part of an organisation’s regular tax governance activities; or
2. In response to Inland Revenue-initiated audit/review activities, provided the scope and timeframe is agreed with Inland Revenue.

Why Participating Advisor?

In contrast to an Inland Revenue investigation, a PAR gives and organisation greater control over timing, access to a team of experts that can identify and implement opportunities (rather than only risks), and more generally, can be scheduled proactively to identify potential gaps, and ensure these are addressed so an organisation is in the best possible position going forward.

What to expect from a Participating Advisor review

Organisations should expect the same comprehensive Deloitte review products, augmented by the confidence of working with an ‘approved provider'. After agreeing and documenting the review scope, our specialist teams will work with organisations through our tailored questionnaire interviews, review of return processes and sample checking. These interviews can be scheduled around a finance team’s busy workflow and in a flexible way to minimise disruption to organisations.  The deliverable is a traffic light report that details the identified risks (and remediation options) and opportunities for an organisation.

Want to find out more?

The Participating Advisor framework officially went live on 1 June 2025 for GST, FBT, and Payroll reviews.

If you would like to know more, or discuss other ways you can strengthen your business’s tax governance, please visit our Participating Advisor webpage, or get in touch with your usual Deloitte advisor.