In this episode of TaxVibe, Robyn chats with Emma Rosenzweig, Deputy Commissioner, Superannuation & Employer Obligations, ATO, about the current landscape of the Superannuation Guarantee regime.
They discuss:
Host: Robyn Jacobson, CTA
Guest: Emma Rosenzweig, ATO
In this episode of TaxVibe, Robyn chats with Emma Rosenzweig, Deputy Commissioner, Superannuation & Employer Obligations, ATO, about the current landscape of the Superannuation Guarantee regime.
They discuss:
Host: Robyn Jacobson, CTA
Guest: Emma Rosenzweig, ATO
Robyn Jacobson:
Hello, and welcome to TaxVibe, a podcast by The Tax Institute. I'm Robyn Jacobson, the senior advocate at The Tax Institute, and your host of today's podcast. We love the vibe of tax, and here at The Tax Institute, we do tax differently. I'll be chatting with some of the tax profession's great thought leaders, who will share valuable and practical insights you may not hear every day. We hope you enjoy this episode of TaxVibe.
Robyn Jacobson:
I'm joined by Emma Rosenzweig, deputy commissioner, superannuation and employer obligations at the ATO. Emma is responsible for ensuring a complex ecosystem of employers, workers, and retirees, and superannuation funds operates efficiently, supporting willing participation, and safeguards entitlements. Emma has worked for the ATO for 23 years in a range of roles, across nearly all areas of the organization, including client engagement roles focused on small business and employers, law roles, including the design and drafting of legislation, and leadership of the ATO's service strategy design and implementation. Emma is passionate about developing leaders of the future, and invests time in mentoring and coaching individuals and groups. She holds a bachelor of laws, a bachelor of commerce, and a masters of tax. Emma, warm welcome to TaxVibe.
Emma Rosenzweig:
Thanks so much Robyn, I'm pleased to be here.
Robyn Jacobson:
So today, we're going to have a chat about the superannuation guarantee regime which amazingly is 30 years old this year.
Emma Rosenzweig:
It makes me feel old.
Robyn Jacobson:
It makes us all feel old. So this is a very complex area, and it remains challenging in terms of law and practice for employers and employees, and dare I even say, the ATO. So if we just start with the general landscape, and I had a bit of a hunch around what is referred to as the SG gap. Now this is essentially what the ATO estimates is the amount of super that is not being paid for employees, and if we look at the '18/'19 estimate, we're talking 3.8%, nearly 4%, or two and a half billion dollars. Now, I've heard figures that range anywhere between two to three billion, depending which year and which report you're looking at and who's running it.
Robyn Jacobson:
We also know that total employer contributions in 2021 according to the Australian National Audit Office Report, was issues recently, was just over 74 billion. So we're talking huge dollars. That's a huge amount going in every year, and most employers get it right; but we've still got ongoing challenges with the employees who are not getting their proper entitlements.
Emma Rosenzweig:
That's right, and I think many of your listeners would be really familiar with the tax gap that we do, and so the super guarantee works similar, where we're trying to look at the system at a really high level and see how well it's working. So one angle you'd say a 3.8% gap is a pretty effective system. As you said, most people are doing it right. Unfortunately with superannuation, those 3.8% of people or two and a half billion dollars are actually people who haven't had super paid for them. And so we take that very seriously, and think about that quite differently to how we think about the tax gap. Because we're really conscious that we have a role in actually ensuring that employees get money into supers, so we're working for them in a sense, which is quite different in a tax context.
Emma Rosenzweig:
So it is a lot of money still. There are a range of reasons why we know that employers get it wrong, and haven't paid those amounts, and they range from everything from simple errors with payroll; payroll as you know is very complicated, so getting it wrong slightly in payroll, through to having cashflow issues and finding it hard to pay, right through to deliberate nonpayment of super, and into things like shadow economy and cash wages and those sorts of issues. So there's a real spectrum of reasons why employers might not have paid the right amount of super for their workers.
Robyn Jacobson:
And the way you just described that then Emma is how I've always described the three categories of employers who don't get it right. Some are the honest mistakes, some are just business challenges, and the third one is the more egregious. The issue with the system is that regardless of the reason why it wasn't paid or the best intent of the employer or otherwise, if someone is just one day late, someone who pays it a day late or got an arithmetic calculation wrong is treated the same way under the system as someone who effectively never pays it for their employer, assuming of course that the ATO is never advised of this.
Emma Rosenzweig:
Well to a degree they are, yes. So the super guarantee rating is pretty strict, because it's employee entitlement. So it is designed fairly strictly for that reason. The scope the ATO does have though is in penalty rating. So the law imposes penalties at 200%, which is a huge amount, and then we have the scope to remit those penalties down. Where we can make a difference is actually looking at exactly what we've just been talking about: what has the behavior of the employer been? Have they tried to get things right? Are they engaging with us when we come and talk to them, and ask them about this? Have they voluntarily disclosed, have they come forward and said, "We've got it wrong." And also what's their compliance history? Are they regularly someone who doesn't pay, or is this a one off and generally they're really good at getting it right?
Emma Rosenzweig:
So our practice statement on this actually really tries to reflect that, but to the extent we've got scope in the super guarantee regime to consider an employer's behavior and where they sit in that spectrum, we will. And so really encourage those people who are at that honest mistake end to come forward, to be really proactive about fixing it up and working with us. And in those cases, those penalties go right down, people who come forward and voluntarily disclose in time have a zero penalty, [inaudible 00:06:26] penalty usually. So that's where we have some scope within the law we're given to work with to reflect what we've just been talking about.
Robyn Jacobson:
The difficulty in that respect, and I think there's still a lot of confusion about what the ATO has the power to do, and on many occasions there are unrealistic expectations that you can, because it's reasonable to do so, you can just get rid of the SG charge. That of course is the shortfall plus the interest plus the admin component, and there's no discretion whatsoever. But in terms of the amnesty period, and I don't propose that you go and unpack all of that here, but the ATO is unable to remit below 100% where the shortfall relates to a quarter that fell within that amnesty period. And that can really be an issue where, for example you've got a closely held payee arrangement, so it's the owner of the business who may not have paid super for themselves, didn't realize they had to, didn't think that it was a priority, were happy to forgo paying salaries and wages or directors' fees. They still have an obligation, so there are still some ongoing challenges with limited discretion in that respect.
Emma Rosenzweig:
That is right. So we are limited in how much we can remit as you said for those amnesty periods. And the amnesty was available for quite some time, and there's a sense that employers had a chance to come forward. I would say in relationship to those closely held, tight arrangements you're talking about, we'd really encourage people to get things right, but they're not the highest risk cases that we are out looking for either. So in that sense, I hope people get that right for themselves, but they're not probably the ones we're actively out looking for in terms of our ability to chase people up.
Robyn Jacobson:
Can you comment briefly on the visibility and the sort of data [inaudible 00:08:11] connects us now? There've been some major changes in the way that information is reported to the ATO or otherwise. I'm interested in your thoughts on that.
Emma Rosenzweig:
Well look, it's something we've been really passionate about, trying to make sure people can access information about their super. We know a lot of people often put their head in the sand a bit about super; it feels like a long way off, especially for young people who can't imagine ever being old. And so one of the things we try to do is make sure it is really easy to see all that information in one spot. So what people can see now as they're logging in through ATO online, if they do their own tax return that's a great time to check while you're in there doing your tax return. If not, I would encourage people to go on once a year and have a look. You log in through ATO online, you can see the latest total super balances for all your super accounts that was reported to the ATO.
Emma Rosenzweig:
Now, we get the total balance only once a year, so obviously that's not always the most current, but it's the last one that we had. But then we also display the regular contributions that are coming into your super account, so you can see those contributions as well. And so it's a great way for people to double check whether their employer is actually making contributions to their super for them, and we would encourage people to go and check that before they come and report to us that their employer hasn't been paying. So obviously as I said, those balances are only, the total balance is only updated once a year, because that can be impacted by investment returns and all of that [inaudible 00:09:40]. So as long as people understand that, they can also use tools to compare their super fund. We now have the MySuper Comparison Tool on the site as well, so you can compare how your fund has performed against others if you're in a MySuper product. And so I think there's some really good tools there to help people sort of get that macro picture of what they've got, see how many accounts they've got and how they're going.
Robyn Jacobson:
So while you're lodging your tax return, check your tax and then check your super.
Emma Rosenzweig:
That's right, if you're doing it yourself. Obviously if you're using an accountant or a tax agent, something that's perhaps a bit more out of patent because you're not going in and doing it yourself, but it would be a great for your listeners who might all be tax agents to encourage their clients to go and check their super as well at that time.
Robyn Jacobson:
A lot of employees now, or members of funds receive monthly notifications from their fund to say when contributions are turning up if they're paid monthly, and often there are required [inaudible 00:10:35] changes, so that's another good reason to go into these member portals and have a look at the super balance at the same time.
Emma Rosenzweig:
That's right. Well, a lot of funds have really invested in that as well. So not only can you go in through the ATO and see; you can obviously go in through the super fund and see it there, so I think that's great.
Robyn Jacobson:
And single touch payroll reporting is also assisting in this respect?
Emma Rosenzweig:
That's right, so people can now see as well as their super, they can see their regular payments from their employer. So back in the old days, not that long ago, but you'd get once a year, you'd get your payment summary from your employer. Now you can actually see live what your employer has reported to us through single touch payroll earnings, and what they've withheld for you, so people can keep track of that so you can do a bit of comparison of what have I been paid, and what sort of contributions have gone in. So yes, STP is really creating much more regular visibility of those amounts for people.
Robyn Jacobson:
I want to turn to some of the ongoing challenges that are inherent in the system, and these fall into different categories. So we've already acknowledged that most employers try to do the right thing, but there are still some ongoing challenges. The employee versus contractor, I don't think in the brief time we have available we are going to possibly solve that one, but it does remain an area of contention for both workers and businesses alike.
Emma Rosenzweig:
It sure does. We're definitely not going to solve that in half an hour, Robyn. It is a complex issue; it's based on common law, so there's a range of criteria, and it's very, very dependent on the actual facts and circumstances of the arrangement people have in place. So it's one where we can give guidance about our interpretation of that, but we can't give black and white answers about if you do it like this, the outcome will be... because often it's so dependent on those unique circumstances that people have. So we've even seen a couple of cases recently at the High Court on this issue, so still despite being a very, it's a longstanding issue, there are still cases that are getting to the High Court which are really fundamentally about these questions, and I think that just shows how complex it is.
Emma Rosenzweig:
One of the things we try to do, we have an Employee Contractor Decision Tool on our website that people can use. They don't have to, it can just be treated as guidance, but it is trying to help people to navigate that decision making. And I would say if you try and use that tool and perhaps you aren't clear on some of the answers to some of the questions because they're a bit gray, your circumstances, you're not quite sure, it really is a scenario where I would recommend people get some good advice on this, because it is so complex.
Robyn Jacobson:
And also the issue that if you do get it wrong and you have to unwind the arrangement from a tax perspective as well as a commercial perspective, of course the penalties, which we'll get into shortly, can be quite severe. I also wanted to talk to you about the ATO's Small Business Superannuation Clearinghouse. This operates in terms of timing quite differently from the commercial clearinghouses that are available to employers, and it's essentially that you can make your obligations by paying the clearinghouse run by the ATO by the 28th day following the end of the quarter. But through commercial clearinghouses, you actually have to make sure it goes through the clearinghouse into the fund by that date. Why the difference, and what concerns does that cause employers in practice?
Emma Rosenzweig:
Yeah, well so obviously the ATO's Small Business Clearinghouse has got some rules about who can use it. So it is designed to be a very simple service for small employers, and it was created at a time when choice was first brought in, and we wanted to give employers the opportunity to have a basic and simple free service to use. I think since then, there are a lot more clearinghouse services in the market, and lots of different offerings now, and so employers have a really wide variety of options.
Emma Rosenzweig:
The ATO's clearinghouse specifically in law has that exemption you talked about, so if employers pay to use the Small Business Clearinghouse we run, it's treated as having been received at that point in time, and that was specifically put into the legislation. So I often get asked the question of, can't you make the other clearinghouses have the same rule? That would require legislative change. It goes back to making sure, ultimately it's the employer that has that responsibility to get their money into super for their employees, so it really ties back to that fundamental obligation of making sure the money goes in, and making sure the ATO I guess has tools to follow it up if it hasn't. So it is a big difference.
Emma Rosenzweig:
It is a question we get asked a lot. I would really encourage employers who aren't using that service, who might be using a commercial service or one as part of the funds that they use. Often where we see people have problems is where there's been some change to the data that they're providing a clearinghouse, so a lot of employers know the sort of timeframe they need to make sure the money gets into a super fund in time. I'd encourage you not to leave it to the last minute. That would be my first tip, don't make payments at the last minute. Make sure there is that time and you understand what those service standards are with the clearinghouses.
Emma Rosenzweig:
But if you've got a change in your data, so if you've got a new employee that you've brought on or if one of the super funds has changed, that's where often data errors can occur and things bounce back, and issues arise. And they're the sorts of scenarios I would make sure people have even more time. If you're taking on a new employee, maybe make an out of pattern payment to their super fund through the clearinghouse so that you can just check that it's all gone through smoothly and you've got the data right. So I'd just think about making sure you've got plenty of time to get those payments in.
Robyn Jacobson:
In my travels around the accounting profession and the tax profession for many years, there still seems to be a lack of awareness by employers in particular as to the severity of the penalties under this regime. It's not simply a case of a bit of interest if you don't pay tax on time, and of course we'd never condone you not paying tax on time, but it is a far greater penalty or outcome that you can experience as an employer by not doing the right thing here. And I'm not trying to do all the doom and gloom, but when you run through this list of what the ATO has been given the power to do under the law, it clearly indicates a policy intent from various governments over the years to address the nonpayment of super. So of course you've got the shortfall itself with the interest and the admin, which is our SGC. You've talked about the 200% penalty, the Part 7 penalty, which can be remitted down to zero in most cases.
Robyn Jacobson:
Then if you don't pay the SGC on time, you've got the general interest charge. There is a separate 75% admin penalty, which we tend not to see it very often because the rest of it's bad enough. The ATO can issue an entity with an estimate to pay the super if they think it hasn't been paid. Directive penalty notices can be issued, and I'm going to look back to it in a moment, because I know there's been some increased activity there. You lose the deductibility of the contribution once it's SGC. There can be a direction to pay it, and noncompliance with that then becomes a criminal offense. There can be a direction to undertake a course to be a better employer, garnishing notices, and if all that wasn't enough, there's the moral obligation of doing the right thing by your staff. So that's an awful lot of arsenal in your toolbox.
Emma Rosenzweig:
It sure is, and I think if people would've seen the last couple of years like all of our debt collection and our enforcement, we have had a bit of a pause on certainly some of the firmer action things you've talked about, so garnishing and directive penalty notices. So some of those much more serious type actions. We've still continued to collect super guarantee, but we probably haven't used all those tools in our kit to their full extent over the last couple of years. And a couple of them were actually reasonably new when the pandemic started; so some of them we actually haven't much of a chance to really test out yet and see how well they work in different scenarios.
Emma Rosenzweig:
It's something that we are really thinking very seriously about now as we're starting to normalize ordinary debt collection arrangements, but also how we make sure that we think about what are the right tools to use in the right circumstances, ultimately with a view to getting super into accounts for these employees. That's the ultimate goal we want. We're not here looking to penalize people, looking to put businesses in a really difficult position. That's not something that we take any pleasure in at all. But sometimes, those tools give us different ways of getting those outcomes. So you mentioned directive penalty notices; we have really ramped up our activity on that generally, but they are a key tool in the superannuation context where directors can be held personally liable for those amounts, and it gives us the capacity to go behind and then actually potentially collect. We're issuing about 120 of those a day at the moment, so that's a significant increase in that activity.
Robyn Jacobson:
And it's not just SCG. Of course that includes PAYG withholding and GST?
Emma Rosenzweig:
That's right.
Robyn Jacobson:
I'm going to hesitate; I think it's luxury car tax was also included in [inaudible 00:20:02].
Emma Rosenzweig:
You might test me on the luxury car tax one, but yes. It's a range of those liabilities that we can issue directive penalty notices for. Don't quote me on the luxury car tax one. So yes, 120 of those a day is a really huge ramp up in activity for those, and obviously they are very serious. They don't get issued without warning, so directors are certainly advised, and they don't get issued without attempts to collect from the entity itself as well. So they're definitely not a first step. We're quite a few steps into trying to engage with a business before we get to a directive penalty notice.
Robyn Jacobson:
So these would generally start to appear when there's been a lack of engagement by the taxpayer, in this case being the employer?
Emma Rosenzweig:
That's exactly right. And as I said before, the easiest way to work with us if you've got any liability, but particularly super guarantee ones, to come forward, talk to us. We've got lots of scope to enter payment plans. We're really keen to work with people to make sure this money comes in, in as easy a way for them as for us. And so that's our message across the board; to come and work with us. We can't help you if you don't come and work with us.
Robyn Jacobson:
So there are some recent changes that kicked in from 1 July this year, and these are legislative changes that moved through the Parliament prior to this year's election. Can you run us through the two major changes that employers will now need to be dealing with?
Emma Rosenzweig:
Sure. So for super guarantee there were two big changes. So there is a bit of a program for super guarantees increasing the rate year on year until it gets to 12%, so that's the ultimate point at which that would stop. So this year on 1 July, the rate of super guarantee went to 10 and a half percent from 10, so it's gone up a half a percent. And the other big change is that there used to be, used to have to earn $450 a month from your employer before you were entitled to super guarantee, and that's been removed. So you are now entitled to super guarantee from every dollar you earn right from the beginning. So the only caveat is, just because super's never easy and simple, is if you are under 18 you still have to work the 30 hours a week to be entitled to super. So while the $450 has gone, under 18 still have to work their 30 hours before they're entitled to super.
Robyn Jacobson:
I think that's important to note, because I have heard of the two rules being conflated, and the 450 monthly income threshold was quite a different rule to the under 18s rule.
Emma Rosenzweig:
Absolutely, and so that's why I mentioned it, because I know it's something that people are getting a bit confused about.
Robyn Jacobson:
So what does an employer do if, let's say you're employing me and I've been working for you for several years. And I did some work for you in June this year which actually fell into a pay period where I received my salary wages in let's say early July. Does that amount of salary and wages attract the old rate, or the higher rate of 10 and a half percent?
Emma Rosenzweig:
I'm glad you asked this, because this is a question that we're getting a lot, and it is really confusing. So you work out your entitlement to super guarantee at the point in time I pay you for the work. So not based on when the work was done, but at the point in time I pay you, that's when I have to work out [inaudible 00:23:21] entitled to super. And so if I pay you in July and you are entitled to super, you're entitled to 10 and a half percent even if some of that work was done in June.
Robyn Jacobson:
But conversely, there was a pay period in late June that actually took a couple of weeks of July into account, just because the work's being done in July doesn't mean that attracts 10 and a half percent. That would still be paid at 10%.
Emma Rosenzweig:
10%, that is exactly right. So it's at the point in time you are paying the salary and wages, not at the time you're paying the super contribution. So in your example there, if I paid you in June, your salary and wages in June for work that was done say in May and June but I didn't make your super contribution to your fund until late July, it's at the point in time I've paid you the salary and wages that you calculate the entitlement to super. So when I go and pay the extra super contributions to your fund in July, I'm paying at the 10% amount. So it is a bit confusing about timing. I just think remember, work it out at the point in time you're paying the salary and wages and you should be right.
Robyn Jacobson:
I feel like over the next few years employees are going to get really good at this, because it'll be going up every year by half a percent until 2025. But because we sat at nine and a half percent for so long, it's a bit of an adjustment to change the way it's worked out.
Emma Rosenzweig:
I think that's right.
Robyn Jacobson:
Also I think worth noting, and this is outside your policy space of course, but the current government has indicated they would like to have a conversation in this current term of Parliament about potentially increasing it beyond 12% even up to 15% in a future term of Parliament. Now, that's obviously on the agenda right now, but it's going to be really interesting to see how that plays out, and ultimately when we keep getting these increases in the rate of SG, in some cases it's borne by the employee if they happen to be on a salary package. But in other cases, the employer takes that burden, if for example it's wages plus super. So you're not going to have a one-size-fits-all as to who's ultimately paying for these increases.
Emma Rosenzweig:
No, that's right, and if that happens, I would just get even better at explaining it I think Robyn, I'll be really well practiced by then. That's my way of not answering your policy question.
Robyn Jacobson:
No, that's fine. So in terms of moving forward from here, you'd talked about the ATO returning to normal debt collection practices. We acknowledge still that many businesses have some cashflow challenges. We know supply chains are taking a bit of disruption at the moment. We know that there are still huge pressures on labor forces, with people being ill and therefore revenues are affected. That in turn affects cashflow. So the main message from the ATO in terms of how you can support the employers through this difficult period?
Emma Rosenzweig:
Look, we do know it is still difficult. As I said before, we can't support you if we can't engage with you, so my best advice would be if you are struggling to come forward and work with us. The other challenges though in the super guarantee context, we do take this quite seriously, and we treat it differently to other debts as well. We prioritize it differently, and when we're looking to collect we certainly don't have minimum amounts or anything like that, minimum levels where we don't look at. So we do really take the collection of super guarantee seriously, because as I said right at the beginning, it is contributions to future retirement for workers, and so we feel very responsible for that.
Emma Rosenzweig:
So I would encourage businesses not to treat those amounts as easy cashflow, because ultimately while you deal with the ATO if you haven't paid it, ultimately it is your employee's money that you are using, and if you can't pay it it's your employees that are missing out. So I would really encourage businesses to make sure that it's part of their thinking about how do they get through tough times. Payroll, so thinking about the people who are working in their businesses and the importance of making sure that they get what they're entitled to.
Robyn Jacobson:
I really like that messaging Emma, because we can debate the merit or otherwise of paying withholding on time or at all, or paying payroll tax or work cover premiums. Essentially they are more regarded as taxes or employment costs by the business. But when you're not paying super, it's like not paying wages.
Emma Rosenzweig:
That's exactly right Robyn, it is like not paying wages. That's the money that your employees are going to have to live on in their time, and it's what they're entitled to, and I would encourage businesses just to really think about that and think about that as they're managing the priority of all those other pressures that you've just talked about that they have.
Robyn Jacobson:
And unfortunately it can effect younger employees to a greater extent, partly because they're often more heavily involved in casual labor. So whether it be hospitality or construction, which tend to be some of the main industries that are typically in the gap, but the second reason is if you don't pay a thousand dollars of super when someone's 20 years old, I'm not going to quickly do the compounding maths, but that's going to be worth significantly more 40 years from now. So they're missing out not just on the contribution going in, but the benefit of the compounding earnings over the period that it should be in the fund.
Emma Rosenzweig:
That's absolutely right. I mean, super is all about time value of money, and it's really important, and you often hear advisors recommending even if you can contribute small amount yourself from a very early stage, they add up, so it's absolutely right. I think one of the challenges we often see too is that younger people or people who have multiple jobs or casual jobs perhaps aren't as engaged about checking up on their super and whether they're being paid the right amounts, or perhaps scared to raise those issues with their employer if they haven't been and they're worried they won't get to. And I understand that that's a really hard... there's not an easy answer to that one. That is a really hard position. I would encourage people to think of this as money. They are entitled to it. It is like unpaid wages. It's almost unpaid future wages if you think about it like that. And if they do find that they're not being paid the right amounts, please come and tell us. We review every single complaint we get about unpaid super, and we take them very seriously.
Robyn Jacobson:
That's really good to hear. Final comment. Can you remark on what's happening with STP phase two, which is the next rollout of STP reporting for employers?
Emma Rosenzweig:
Sure. So this is, we've got most employers now reporting through STP, which is fantastic. So it is the primary way we now pre-fill individuals' tax returns. STP phase two is about breaking that reporting up into more granular detail, and we're sharing that data with Services Australia so they can use it to do things like pre-fill claim amounts for their clients, or to support their clients getting the right amount of payments throughout the year. So it's really important from that respect that employers get this right.
Emma Rosenzweig:
Where we're at too is employers are reliant on their software being updated to be able to report like this, so employers should know from their software provider when their package will be ready to go. We've got a bunch of them that already are, and a bunch of employers that are already reporting through STP2, but there are some that still aren't, so we've been working with software providers to make sure over the course of the year that they're updating their products. So first step is know when your software is going to be ready, but I have heard comments, a lot of employers saying, "Oh, this is all just something the software would do, isn't it? I don't need to worry." But actually there are things that an employer can do in advance to be ready. So making sure that you understand the right pay codes to report, or the different bits of pay in. So allowances and those sorts of things, different types of leave, getting that right.
Emma Rosenzweig:
So making sure at the backend your record keeping is really good, and is going to meet the needs of putting the information into the software. So quality data in, means quality reporting to us, means accurate information to services Australia to support your employees. Check the date your software's ready, and most software providers have got information up about what do you need to do in advance to be ready, so that when the software's ready to go, you're ready to transition. So I'd encourage employers to do those two things.
Robyn Jacobson:
Emma, you have an enormous responsibility looking after all these employer applications, and of course superannuation, so thank you so much for your time.
Emma Rosenzweig:
You're very welcome Robyn, thank you for having me.
Robyn Jacobson:
Thanks for listening to this episode of TaxVibe. I've been chatting with Emma Rosenzweig, deputy commissioner, superannuation and employer obligations at the ATO. Have you heard about the tax summit? In case you're not aware, our flagship event is coming up from 19-21 October at the ICC Sydney. Join us for a unique three day experience, and the best tax event of the year. Check out the full program featuring more than 100 presenters across more than 65 sessions on our website. We've also got some great discounts available if you purchase your ticket now, so head over to our website to find out more.
Robyn Jacobson:
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