Reportable tax position schedules
1 April 2021
As a mechanism to help detect and prevent high risk arrangements and tax avoidance schemes, the largest public, multinational and private companies have to complete a reportable tax position (RTP) schedule that contains information about uncertain tax positions and potentially risky arrangements that were entered into.
Impacted organisations must lodge an RTP schedule with their tax return each year even if there are no reportable tax positions to disclose.
The RTP schedule consists of three categories:
Category A discloses material uncertain positions that are less likely to be correct than incorrect or as likely to be correct as incorrect even if these positions are reasonably arguable.
Category B discloses material tax related provisions, current tax liabilities or contingent liabilities.
Category C discloses specific arrangements of concern (as set out in taxpayer alerts and practical compliance guidelines) and self-assessed risk ratings of these arrangements of concern as set out in the various ATO practical compliance guidelines (PCGs).
Public or foreign-owned companies that must lodge an RTP schedule (i.e. lodgement based on self-assessment) are businesses with total business income of:
$250 million or more; or
$25 million or more provided they are part of a public or foreign owned economic group with total business income of $250 million or more.
This is the first year that large private companies with total business income of $250 million or more or $25 million or more (provided they are part of a private economic group with total business income of $250 million or more) will have to lodge a RTP schedule for the year of income commencing on and after 1 July 2020, but only if the ATO notifies them to do so (i.e. lodgement not based on self-assessment).
From years commencing on and after 1 July 2021, the lodgement of RTP schedules by private companies will also be based on self-assessment.