From Tax Time 2026, the Reportable tax position (RTP) schedule obligations will apply to large APRA-regulated super funds and large collective investment vehicles (CIVs) that have:
- total business income exceeding $250 million
- met the lodgment criteria set out in the relevant RTP schedule instructions.
This inclusion aligns with our differentiated approach to obtaining justified trust for the superannuation and collective investment vehicle (CIV) industry, both for significant and general pool taxpayers.
By increasing the scope and regularity of self-disclosure obligations on large APRA-regulated super funds and large CIVs, we can:
- promote a level playing field by ensuring super funds and CIVs have the same obligations as companies to disclose their most contestable and material tax positions
- improve our focus on maintaining high levels of assurance and continue to detect and treat areas of low assurance
- continue to streamline our information gathering process and tailoring our engagement with taxpayers
- make informed decisions about future engagements with taxpayers
- enhance our treatment strategies and ability to monitor income tax risks that arise in the super fund and CIV income tax space.
The RTP schedule will be referrable to our public advice and guidance (PAG) on emerging superannuation and CIV risks and areas of uncertainty. This will provide greater visibility regarding any entrenched and emerging risks across all market segments.
RTP schedules will be due with the relevant income tax return lodgment and will constitute an approved form.
ReportableTaxPosition@ato.gov.au
pgsuperannuationriskandstrategy@ato.gov.au
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