The Australian Bankers’ Association submission on APS 110 and APG 110

The Australian Banking Association (ABA) supports the Government’s introduction of an economy-wide cash payment limit to businesses for goods and services. Having a taxation system that is robust and one that meets community expectations is vital and we recognise the importance of this initiative to the integrity of our tax system.

We acknowledge The Australian Securities and Investments Commission’s (ASIC) intention to provide ‘high level’ guidance, and to rely on the ordinary meaning of ‘significant detriment’. However, for the efficient implementation of this measure, maximum clarity around the meaning of this term is desirable.

Banking will be the first sector to apply the Consumer Data Right and the ABA supports the participation of more sectors over time to achieve an economy-wide open data regime.