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  • Treating similar arrangements or transactions as a single position

    Similar arrangements or transactions are treated as a single position when both:

    • the facts used to determine their treatment for tax purposes are the same or similar, or are related to each other in a way that makes it necessary to take them into account together
    • a common conclusion is reached on their tax treatment, that is, there is a common basis for lodgment.

    These arrangements or transactions only need to be disclosed on the schedule once under a single RTP number. You must state in the Concise description field that the position relates to more than one similar arrangement or transaction.

    Research and development tax offset claims

    An R&D tax offset claim reflected on the tax return may not be a single Category A or B reportable tax position. Instead there may be several positions taken within the R&D tax offset claim, for example, whether the:

    • entity is an eligible R&D entity
    • expenditure included in the claim was incurred
    • expenditure was incurred on eligible R&D activities
    • expenditure was at risk for R&D purposes
    • feedstock provisions are applicable.

    Each of these positions must be considered separately to work out whether your entity has any material reportable tax positions you must disclose on the schedule.

    If your entity has several projects that make up its R&D tax offset claim, this doesn't mean each project is treated as a separate Category A or B reportable tax position. If the criteria for treating similar arrangements or transactions as a single position are met, you only need to report the projects under a single disclosure.

    Related party international dealings

    Where your entity has multiple related party international dealings, if the criteria for treating similar arrangements or transactions as a single position are met, you only need to report the dealings under a single reportable tax position disclosure.

    You can also combine all related party revenue dealings, or related party expenditure dealings, as a single Category A reportable tax position disclosure.

    Last modified: 25 Aug 2021QC 65144