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RTP schedule expansion to large private companies

Guidance on the obligation for large private companies to lodge a Reportable tax position (RTP) schedule.

Last updated 29 May 2023

About the expansion

This information will assist you in meeting your obligations to lodge a Reportable tax position (RTP) schedule, including your disclosure obligations.

All companies need to lodge an RTP schedule for years beginning on or after 1 July 2021 if they meet the RTP schedule lodgment criteria. This is the same for all types of companies, whether private, public or foreign-owned.

Entities that are not companies, who are required to lodge company tax returns, don't need to lodge an RTP schedule. For example, a corporate limited partnership is not required to lodge an RTP schedule.

For years beginning between 1 July 2020 and 30 June 2021, private companies only need to lodge the RTP schedule if we have notified them of the requirement to do so. The notification letters were issued in July and September 2020.

If you have questions or require further information, email us at ReportableTaxPosition@ato.gov.au.

Lodgment criteria

To access the RTP lodgment criteria see Who needs to complete the schedule? in the RTP schedule instructions.

Lodgment requirements

Private companies are required to lodge the RTP schedule for their:

  • 2021–22 and later income years if they meet the RTP lodgment criteria
  • 2020–21 income year if we have sent them a notification

2021–22 and later income years

You need to lodge an RTP schedule for the 2021–22 income years if you meet the RTP schedule lodgment criteria. This is the same for all types of companies, whether private, public or foreign-owned.

2020–21 income year

You need to lodge an RTP schedule for the 2020–21 income year if we have sent you a notification of the requirement to lodge. If you have an early balancing substituted accounting period, your first RTP schedule will be for the 2021–22 year. If your private company was not sent a notification, it is not required to lodge a 2021 RTP schedule.

Substituted accounting period

Large private companies with an early balancing substituted accounting period (SAP) starting before 1 July, will:

  • not be required to lodge an RTP schedule for 2020–21
  • be required to lodge an RTP schedule for 2021–22 if they are notified
  • be required to lodge an RTP schedule for 2022–23 and subsequent years if they meet the lodgment criteria.

Large private companies with a late balancing SAP starting after 1 July, will be required to lodge an RTP schedule for:

  • 2020–21 if they are notified
  • 2021–22 and subsequent years if they meet the lodgment criteria.

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