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  • Introduction

    These instructions help you complete the Reportable tax position schedule 2019.

    What's new

    We no longer notify every taxpayer who is required to lodge an RTP schedule. You are required to lodge an RTP schedule if you meet the criteria.. We will continue to notify specific taxpayers who do not meet the criteria that are required to lodge a RTP schedule.

    To support the transition to self-assessment we invite you to email the RTP mailbox at ReportableTaxPosition@ato.gov.au should you have any concerns regarding your lodgment obligations.

    How we use information on your schedule

    We use schedule disclosures to:

    • tailor our engagement where we focus and work with you on complex high risk arrangements
    • identify areas where we need to provide further clarification or certainty on the correct treatment of transactions and complex high risk tax arrangements
    • better understand tax risk for taxpayers, industries and the large market
    • improve dialogue with large businesses about their risk profile and corporate governance
    • allow you to make informed decisions about positions you have taken or are considering taking that are considered to be high risk arrangements.

    We review your disclosures and work with you to provide an indication of how we will respond to each disclosure.

    RTP Category C is updated throughout the year. We recommend you use the electronic version of this document to ensure that you are reporting on the most up-to-date list of RTP Category C questions.

    Who needs to complete the RTP schedule

    You need to complete the RTP schedule if we have notified you in writing that you are required to complete the RTP schedule or you meet the criteria:

    • you are lodging a tax return for the year ending 30 June 2019 or later
    • you are a public company or a foreign-owned company and      
      • your total business income is $250 million or more in the current year, or
      • your total business income is $25 million or more in the current year and you are part of a public or foreign owned economic group whose total business income is $250 million or more in the current year or the immediate prior year.

    We have provided examples to help you calculate your group income, work out who is in your economic group and whether you are a public or foreign owned company.

    Exceptions to RTP lodgment requirement

    You are not required to lodge an RTP schedule if you:

    • are not required to lodge an income tax return for the whole income year. This is because the RTP schedule is a schedule to the company tax return.
    • have entered into an Annual Compliance Arrangement (ACA) with us for the relevant income year, and      
      • as part of the ACA you agreed to provide full and true disclosure and ongoing dialogue of all material tax matters including any positions that fall within any RTP category in accordance with this RTP guide.

    You must lodge the RTP schedule in all other circumstances, including where you have no disclosures.

    What positions must be disclosed

    All reportable tax positions must be disclosed in the schedule, unless they meet the exceptions below.

    You do not need to disclose a specific position in the schedule if:

    • you have already applied to us for a private ruling that covers the position, or
    • the position is covered by an advance pricing arrangement (APA) or an application for an APA that has been accepted into our APA program.

    Additionally, you do not have to disclose Category A and B RTPs that are not material or where that position is already disclosed under RTP Category C.

    Where you have withdrawn your application for a private ruling, the application for the ruling no longer exists. If your position is material, and falls within any of the three RTP categories, you must disclose it in the RTP schedule.

    What you must do

    If you are required to lodge a RTP schedule, you must:

    • answer Yes at item 25 of the Company tax return 2019 (NAT 0656)
    • complete the Reportable tax position schedule 2019 (NAT 74066) – the schedule.
    Last modified: 23 Jul 2020QC 58955