How to use these instructions to complete the RTP schedule and find out what's new since last year.
Using these instructions
Follow these instructions to complete the Reportable tax position (RTP) schedule (NAT 74066). The schedule forms part of your entity's tax return.
When we say 'you', we mean you as the person responsible for completing the Reportable tax position schedule 2023.
These instructions aren't a guide to income tax law. You can ask for help from us or a recognised tax adviser if you feel these instructions don't fully cover your circumstances.
What's new?
The following Category C questions have changed:
- Question 7 – red zone has been added to subcategory 6.
- Question 14 – red zone has been added to subcategory 7 and 17. Additional information is requested in the comments.
- Question 23 – red zone has been added to subcategory 7.
- Question 24 – minor change to subcategory numbers.
- Question 34 – minor wording changes.
- Question 35 – subcategory 1, 2 and 3 added to the question.
- Question 37 – red zone has been added to subcategory 6, 16 and 26.
- Question 39 – subcategory 8 has been modified with red zone added and subcategory 9 removed.
The following Category C questions are new:
- Question 41 – Treaty shopping arrangements or to obtain reduced withholding tax rates (TA 2022/2).
- Question 42 – global intangible low-taxed income (TD 2022/9).
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 (12 months or more)
- 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 an economic group with total business income of $250 million or more in the current year.
If your entity meets the criteria, you need to lodge the schedule even if it has no disclosures. You may still need to lodge the schedule even if your entity doesn't meet the criteria. We will notify you if this is the case.
We have provided examples to help you:
- calculate your entity's group income
- work out who is in your entity's economic group
- assess if you need to lodge an RTP schedule if your entity is lodging a stub return.
For large private companies see RTP schedule expansion to large private companies.
Exceptions to lodgment requirement
You are not required to lodge the schedule if your entity:
- is not required to lodge a company tax return for the income year (the RTP schedule is a schedule to the company tax return)
- has an income tax annual compliance arrangement (ACA) with us for the relevant income year and has agreed to provide
- full and true disclosure
- ongoing dialogue of all material tax matters, including positions that fall within any RTP category.
If you are uncertain if your entity is required to lodge the schedule you can email ReportableTaxPosition@ato.gov.au.
Positions you need to disclose
You only need to disclose Category A positions that exceed your entity's materiality amount.
All Category C positions must be disclosed in the schedule.
If your entity is the head of a tax consolidated group, you need to disclose positions that meet the requirements to be an RTP under categories A, B and 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 an RTP schedule, you must answer Yes to item 25 of the Company tax return 2023.