Reasonable measures include: Taxpayers should provide supporting evidence to demonstrate that reasonable compliance measures have been taken. Failure to lodge (FTL) penalties can reach up to A$825,000. While each entity with a lodgment obligation could be penalised individually at law, the ATO will remit penalties during the transitional period to: Remission is conditional on demonstrating reasonable compliance measures. The ATO may still impose FTL penalties in cases involving poor compliance history, fraud and/or tax evasion. The ATO may extend the lodgment deadline for the AIUTR and the DMTR. While it may not extend the deadline for the GIR or the FNF, the ATO may suspend enforcement action if MNE groups take reasonable measures to comply. With respect to errors or mistakes in forms, the ATO would typically not impose penalties during the transitional period if they were a result of unfamiliarity with or a lack of clarity in the rules.