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  • Introduction

    What's new

    We no longer notify taxpayers of their obligation to lodge a Reportable tax position (RTP) schedule. You are required to lodge the schedule if your entity meets certain criteria, even if your entity has no disclosures to make. You may still be required to lodge the schedule even if your entity doesn't meet the criteria. We will notify you if this is the case.

    We have removed the exceptions to disclosing positions covered by private rulings or advance pricing arrangements (APA).

    We have made changes to the definition section of the instruction:

    Who needs to complete the schedule

    You need to complete the schedule if your entity:

    • is lodging a company tax return for the entire year
    • is a public company or a foreign owned company
    • has total business income of either        
      • $250 million or more in the current year
      • $25 million or more in the current year and is part of a public or foreign owned economic group with total business income of $250 million or more in the current year or the immediate prior year.

    If your entity meets the criteria you need to lodge the schedule even if it has no disclosures.

    We have provided examples to help you:

    Exceptions to lodgment requirement

    You are not required to lodge the schedule if your entity:

    • isn't required to lodge a company income tax return for the income year. This is because the RTP schedule is a schedule to the company tax return.
    • has an annual compliance arrangement (ACA) with us for the relevant income year. Under this it agreed to provide full and true disclosure and ongoing dialogue of all material tax matters, including any positions that fall within any reportable tax position category.

    If you are uncertain if your entity is required to lodge the schedule you can email

    Positions you need to disclose

    You only need to disclose Category A and B positions that exceed your entity's materiality amount.

    All Category C positions must be disclosed in the schedule. Category C is updated throughout the year. You should check the Category C questions section of this guide before completing the schedule.

    If your entity is the head of a tax consolidated group, you need to disclose positions that meet the requirements to be a reportable tax position under Category A and B and Category C taken by the head entity or any of its subsidiary group members.

    Completing the schedule allows you to make informed decisions about positions your entity has taken or is considering taking.

    What you must report on your entity's tax return

    If you are required to lodge a RTP schedule, you must answer Yes at item 25 of the Company tax return 2020.

    How we use information from the schedule

    We use schedule disclosures to:

    • tailor our engagement and work with taxpayers to resolve concerns and provide assurance over complex high risk arrangements
    • improve our understanding of the risk profile and corporate governance of taxpayers and how we engage with them
    • identify where we need to provide further clarification or certainty on the correct tax treatment of complex high risk arrangements and transactions
    • better understand tax risks across the large business population.

    We review individual disclosures and work with taxpayers to respond to each disclosure.

    Last modified: 11 Dec 2020QC 61945