Large business and tax compliance publication

Reportable tax position schedule

The reportable tax position (RTP) schedule for income tax is part of our integrated approach to working with our largest business taxpayers. It supports a more contemporaneous review of, and engagement with these taxpayers, supporting increased taxpayer transparency in a targeted and efficient manner.

Our largest businesses must disclose their most contestable and material tax positions.

For the 2012 and 2013 income tax years, the RTP schedule is being piloted with a small number of taxpayers who have been advised in writing that they need to lodge the RTP schedule. Taxpayers that have entered into an income tax annual compliance arrangement (ACA) for the relevant income year will not need to complete the RTP schedule.

RTPs are material and contestable positions that come under one or more of the following categories:

• a position that is about as likely to be correct as incorrect, or is less likely to be correct than incorrect
• a position where uncertainty about taxes payable or recoverable is recognised or disclosed in the taxpayer's or a related party's financial statements
• a reportable transaction or event.

You only need to disclose in the RTP schedule material tax positions that have not been previously disclosed either:

• in an application for a private binding ruling
• under an advance pricing arrangement (APA) or an application for an APA that has been accepted into the APA program
• in a Reportable tax position early disclosure form.

We will use RTP disclosures to:

• better understand tax risk for taxpayers, industries and the large market
• further refine our risk-differentiation framework (RDF) categories to enhance the risk-based choices we make to prioritise our work
• improve our dialogue with large businesses about their risk categories and corporate governance
• help us focus our compliance activities
• identify areas of uncertainty in the tax law that may need
• law clarification or legislative improvements
• further advice and guidance by us.

For more information on how we will use RTP disclosures, refer to Reportable tax position schedule.

Sections within Cooperative compliance

• Taxpayer initiated processes
• Voluntary disclosures
• Self-amendments
• Reportable tax position schedule
• Annual compliance arrangements
• Advance pricing arrangements
• Mutual agreement procedure
• Tax issues entry system