Section C: Category C reportable tax positions – Super funds

How to Complete Section C: Category C RTPs on the RTP schedule for super funds.

Published 20 April 2026

What to disclose in Section C

In Section C you need to disclose Category C reportable tax positions (RTPs). You must complete all the mandatory fields for each RTP you're reporting.

The questions will tell you if you need to consider materiality. When the question doesn't include any materiality criteria, you must disclose a Category C RTP if the arrangement, transaction or circumstances it covers is relevant for your entity.

Unless we specify otherwise, the questions refer to arrangements or transactions:

in place at any time in the income year
that your tax return covers and the schedule accompanies.

You don't need to disclose an arrangement for a Category C question referencing a taxpayer alert if:

we review the arrangement and advise we won't be taking further action
there has been no material change to the arrangement since our review.

Did you have any Category C RTPs for the 2025–26 income year?

You must confirm if your entity has any Category C disclosures.

Select from the drop-down menu, either Yes or No.

If you select No, go to Section D: Declaration and signature.

If you select Yes, the next question will ask How many Category C RTPs you are reporting?

How many Category C RTPs are you reporting?

Write the total number of Category C RTPs you are reporting.

You need to follow the instructions for answering individual Category C questions to ensure you make a complete disclosure.

Using the PDF schedule

In the PDF version, once you enter the number of RTPs you are disclosing and move off the field, it will automatically display the required number of fields to make the disclosures.

Have you discussed this position with the ATO?

For each disclosure you make, you must confirm if you (or another representative of your entity) have previously discussed the disclosure with us. You must complete all fields for each disclosure, no matter what answer you provide.

Select from the drop-down menu, either Yes or No.

RTP Category C question and subcategory

Write the number of the Category C question you are disclosing in the RTP Category C question field. If there are subcategories, enter the relevant subcategory in the RTP Category C subcategory field.

If your entity has multiple positions covered by a single question, the question will tell you how to disclose this. You may need to select the appropriate subcategory or make a disclosure for each position.

For all Category C questions, you must make a disclosure if your entity had an arrangement covered by a question at any time during the year. If the arrangement is no longer in place at the time of preparing your entity's tax return, note this in the Comments field.

Comments

Some questions specify the information you must provide in this field.

If a question doesn't require information in the Comments field, we encourage you to explain your entity's arrangements. Doing so may mean we:

don't need to contact you for more information
can target the questions we ask if we do require more information.

Question 1

If your entity has cross-border related party finance arrangements, disclose the outcome you have self-assessed using PCG 2017/4 ATO compliance approach to taxation issues associated with cross-border related party financing arrangements and related transactions. Use Schedule 1 and/or Schedule 3 for the 3 most material arrangements.

If your entity has a cross-border related party finance arrangement with a higher risk rating to the 3 already disclosed, you must also disclose this arrangement.

Include each arrangement as a separate disclosure on the RTP schedule.

Materiality is determined by the loan amount in Australian dollar equivalent. Use the instructions for question 11 of the International dealings schedule 2026 (IDS) to determine materiality.

For related party debt funding arrangements (inbound interest-bearing, outbound interest-bearing and inbound interest-free loans) rated under Schedule 1:

Subcategory 1: white zone
Subcategory 2: green zone
Subcategory 3: blue zone
Subcategory 4: yellow zone
Subcategory 5: amber zone
Subcategory 6: red zone
Subcategory 7: red zone, if you haven't applied Schedule 1.

For related party outbound interest-free loans under Schedule 3:

Subcategory 11: white zone
Subcategory 12: green zone
Subcategory 13: blue zone
Subcategory 14: yellow zone
Subcategory 15: amber zone
Subcategory 16: red zone
Subcategory 17: red zone, if you haven't applied Schedule 3.

Enter the relevant subcategory number in the RTP Category C subcategory field.

For each of the arrangements you disclose, provide all the information below in the Comment field:

the currency of the loan
the rate of interest (if variable, the base rate and margin)
the Australian dollar equivalent loan amount
if the arrangement is an outbound or inbound loan
If the arrangement has been subject to any review by us, provide our reference number. This can be found in the top right corner of correspondence from us relating to the review. If you have discussed the arrangement with us outside a formal review product, provide details of the discussion.

Question 2

If your entity has reached a formal settlement agreement or future compliance arrangement with us that applies to the current income year, disclose the outcome of your entity's terms of agreement using the following subcategories:

Subcategory 1 – your entity breached one or more of the terms of the settlement deed or future compliance arrangement.
Subcategory 2 – changes in the relevant and material facts, as disclosed in the deed or arrangement, have occurred.
Subcategory 3 – your entity is compliant with the terms of settlement deed or future compliance agreement.

Write the relevant subcategory number in the RTP Category C subcategory field. Write the number 1 if both Subcategory 1 and 2 apply.

In the Comments field, provide details of the circumstances relevant to the subcategory and provide our reference number for the settlement agreement or forward compliance arrangement. This can be found in the top right corner of correspondence from us related to the settlement or agreement.

Question 3

Are you aware of any unamended mistakes or omissions in any single tax return lodged by your entity within 4 years of the lodgment date of this RTP schedule where, if you amend all mistakes or omissions in that tax return, it would result in either:

more than $1.5 million in tax being payable (or would have been payable had it not been offset, for example, by losses from prior income years)
more than $5 million in losses (including capital losses).

For the purposes of this calculation, only count mistakes and omissions your entity hasn't previously notified us of.

In the Comments field, provide details of the mistakes or omissions, the:

tax returns the mistakes or omissions applies to
nature of the mistakes or omissions
amount of tax payable or losses the mistakes or omissions would result in.

Question 4

If your entity has restructured out of any arrangements in the current year to which the hybrid mismatch rules applied, or would have applied had the arrangements remained in place, disclose the subcategory that describes your entity's current position:

Subcategory 1: all restructured arrangements qualify as low risk under Practical Compliance Guideline PCG 2018/7 Part IVA of the Income Tax Assessment Act 1936 and restructures of hybrid mismatch arrangements
Subcategory 2: one or more of the restructured arrangements don't qualify as low risk under PCG 2018/7.

In considering whether the hybrid mismatch rules would apply you must disregard dual inclusion income.

Write the relevant subcategory number in the RTP Category C subcategory field.

For arrangements that aren't low risk, in the Comment field provide:

details of the restructured arrangement
basis on which the arrangement didn't qualify as low risk under PCG 2018/7.

If you have disclosed the details of the restructured arrangement, as part of your disclosure for the income year in the restructures section of your local file short form 2026 or IDS question 49 lodgment, you may refer us to that disclosure in your comments. You are still required to provide the basis on which the arrangement didn’t qualify as low risk under PCG 2018/7.

If you're not lodging your local file short form 2026 together with the lodgment of your tax return 2026, you must disclose the information we require in the RTP schedule about the arrangement.

Question 5

Has your entity claimed deductions for expenses incurred under arrangements with offshore related or unrelated parties and used intangible assets held by an offshore party in connection with these arrangements, where the arrangements don't appropriately recognise an amount as consideration for the use of the intangible assets.

Write the number one (1) in the RTP Category C subcategory field.

Has your entity claimed deductions for expenses incurred under arrangements with offshore related parties and used intangible assets held by an offshore related party in connection with these arrangements, where one of the following subcategories applies:

Subcategory 2: your entity hasn't applied the arm’s length principle in determining the appropriate consideration for the use of the intangible assets.
Subcategory 3: your entity has considered the arm’s length principle in determining the appropriate consideration for the use of the intangible assets, but the arrangement isn't covered by section 284–255 of Taxation Administration Act 1953 (TAA 1953) compliant transfer pricing documentation.

Write the relevant subcategory number in the RTP Category C subcategory field.

If multiple subcategories apply to a single arrangement, record the lowest subcategory. For example, if both subcategories 1 and 2 apply, record subcategory 1.

If your entity has more than one arrangement you will need to disclose each arrangement separately, unless the criteria for treating similar arrangements or transactions as a single position apply. In this case, record the number of arrangements in the Comments field.

For more guidance, see Taxpayer Alert TA 2018/2 Mischaracterisation of activities or payments in connection with intangible assets.

Question 6

Has your entity been part of an arrangement with the description of either:

Subcategory 1: Your entity has subscribed for a controlling share of units in a unit trust (where they didn't own a controlling share in the prior year), which had a debt to another party that was the trust’s associate before the subscription and where the proceeds of the subscription were used to repay the debt?
Subcategory 2: Your entity has or had an associate unit trust which, in the current or 4 previous income years, transferred assets into a second unit trust relying on CGT rollover relief under Subdivision 126–G of Income Tax Assessment Act 1997 (ITAA 1997), and where the unit holdings in the second trust have subsequently changed to the extent that it is no longer your associate?

For more guidance, see Taxpayer Alert TA 2019/2Trusts avoiding CGT by exploiting restructure rollover.

Write the relevant subcategory number in the RTP Category C subcategory field. Write the number 2 if both subcategories apply.

Question 7

In the current, or 4 prior income years, has your entity, or an entity that your entity controls, claimed a full credit or offset for foreign income tax paid where less than 100% of the related foreign income (including capital gains) is included in their Australian assessable income?

For more guidance, see, ATO Interpretative Decision ATO ID 2010/175 Foreign income tax offset: entitlement where foreign capital gain is only partly assessable in Australia.

Question 8

Has your entity entered into any arrangements, or variation of arrangements, described in Taxpayer Alert TA 2020/5 Structured arrangements that provide imputation benefits on shares acquired where economic exposure is offset through use of derivative instruments and obtained imputation benefits relating to a parcel of Australian shares it holds (either directly or indirectly) where it has offset its economic exposure to those shares, or an Australian equities index, through the use of derivative instruments?

Question 9

Has your entity made payments to an entity that is a member of your entity's Division 832 control groups and those payments would, prior to the application of Subdivision 832-H, result in an income tax deduction in the current income year?

Disclose the outcome you have self-assessed using Practical Compliance Guideline PCG 2021/5 Imported hybrid mismatch rule – ATO's compliance approach.

Subcategory 1: white zone
Subcategory 2: green zone
Subcategory 3: blue zone
Subcategory 4: yellow zone
Subcategory 5: amber zone
Subcategory 6: red zone 1
Subcategory 7: red zone 2
Subcategory 8: red zone, if you haven't applied PCG 2021/5.

Write the relevant subcategory number in the RTP Category C subcategory field.

In the Comments field, provide:

if the arrangement rating is red or amber, the reason the arrangement falls in that zone
if subcategory 8 applies, the reason you didn't apply the PCG.

Question 10

During the year, did your entity enter into, or was otherwise involved in, any new cross-border arrangements or structural changes involving intangibles or shareholding interests?

If yes, include in the Comments field:

a brief description of the new arrangement or structural change and the jurisdiction of the counter-party entity or entities involved before and after the arrangement or structural change was implemented
if you obtained, or expect to obtain, a reduced withholding tax under one of Australia’s double tax agreements on any royalties or unfranked dividends paid pursuant to this new arrangement or structural change.

For more guidance, see Taxpayer Alert TA 2022/2 Treaty shopping arrangements to obtain reduced withholding tax rates.

Question 11

If your entity has any international related party Intangibles Migration Arrangements that involves a Migration of intangible assets in the current income year (within the meaning set out in paragraph 3 of Practical Compliance Guidance PCG 2024/1 Intangibles migration arrangements), and the Migration arrangement is not an Excluded Intangibles Arrangement (see paragraph 39 of PCG 2024/1), disclose the risk rating you have self-assessed under Table 1 of the Risk Assessment Framework in PCG 2024/1 for the 3 most material Migration arrangements.

If in the current year, your entity has entered into one or more Migration arrangements with a higher risk rating under Table 1 of the Risk Assessment Framework than the 3 most material arrangements disclosed, you must also disclose each of those other arrangements.

Include each arrangement as a separate disclosure on the RTP schedule.

Materiality is determined using the instructions to question 17 of the International dealings schedule (IDS).

If you're making a disclosure in question 17 of the IDS or in the restructures section of your local file short form lodgment for the current year regarding a restructuring event or new arrangement which is also an Intangibles Migration Arrangement (within the meaning of PCG 2024/1), you can refer to that as one of your disclosures and make the relevant reference in the Comments section.

Write the relevant subcategory number in the RTP Category C subcategory field:

Subcategory 1: Green (lower risk)
Subcategory 2: Blue (lower to medium risk)
Subcategory 3: Amber (medium risk)
Subcategory 4: Red (higher risk)
Subcategory 5: White Zone
Subcategory 6: high risk, if you haven't applied PCG 2024/1.

Note: if an Intangibles Migration Arrangement has been disclosed in question 17 of the IDS or in the restructures section of your local file short form lodgment for the current year, and you refer to that disclosure in your RTP schedule, you don't need to provide the below details to the extent you have already disclosed them.

For each arrangement you disclose, include in the Comments field:

a summary of each arrangement, including the type of arrangement (for example, a sale or licence) and the entities involved
a summary of the intangible assets involved in each arrangement, including a summary of the key connected Australian development, enhancement, maintenance, protection and exploitation (DEMPE) activities
an indication of whether the arrangement has been disclosed in question 17 of the IDS or restructures section of your local file short form lodgment for the current income year.

Question 12

Other than Excluded Intangibles Arrangements (as defined in paragraph 39 of Practical Compliance Guidance PCG 2024/1 Intangibles migration arrangements), if your entity has any international related party Intangibles Migration Arrangements in the current year that didn't involve a Migration of intangible assets in the current year (within the meaning set out in paragraph 3 of PCG 2024/1), disclose whether there is any connection between those arrangements and any prior Migration of intangible assets held by your entity in the last 5 years.

Write the relevant subcategory number in the RTP Category C subcategory field.

Subcategory 1: Yes – one or more current arrangements has a connection with a prior Migration
Subcategory 2: No – none of the current arrangements have any connection with a prior Migration
Subcategory 3: Don’t know whether one or more current arrangements have a connection to a prior Migration
Subcategory 4: high risk, if you don't apply PCG 2024/1
Subcategory 5: Yes – one or more current arrangements has a connection with a prior Migration, and you disclosed this in question 45 of the RTP schedule in a previous income year.

Note: you don't need to provide the below details where you previously disclosed them in the IDS or the local file, in particular:

With respect to your current arrangement – where it has been disclosed in the restructures section of your local short form lodgment in a current or previous year as a new arrangement or restructuring event
With respect to the prior year Migration arrangement that your current arrangement is connected to – where it has been disclosed in question 17 of the IDS or in the restructures section of your local file short form lodgment in a previous income year.

You only need to specify where you disclose this information in the Comments field, specifying the name of the form, question number and the income year.

If you haven't lodged your local file short form 2026 together with the lodgment of your tax return 2026 you must still disclose the information we require in the RTP schedule about the arrangements.

If Subcategory 1 applies, in the Comments field provide for both the current arrangement and any connected past Migration of intangible assets:

provide a summary of each arrangement, including type of arrangement (for example, sale or licence) and the entities it involves
provide a summary of the intangible assets you involve in each arrangement including a summary of the key connected DEMPE activities.

Question 13

Has your entity adopted a tax parcel selection methodology that does not fall within the low-risk arrangements in Practical Compliance Guideline PCG 2018/2?

If your entity has obtained a private ruling on this arrangement, in the Comments field, confirm whether there has been any material differences in the facts of the arrangement to what was presented to the ATO in the course of obtaining the ruling.

Question 14

Has your entity deducted a payment to the trustee of your entity under section 8-1 of the Income Tax Assessment Act 1997, where the payment:

is for the purpose of building or maintain a reserve to address the trustee’s risk, and
is a lump sum, or a number of lump sum instalments, or an ongoing amount that is separate and distinct from its existing ongoing and recurrent charges for trustee services?

See Taxation Determination TD 2024/6 for more guidance.

Question 15

Has your entity entered into any arrangement(s) with the trustee of a non-resident trust that your entity is, or was at any time during the year, a beneficiary of, for the provision or use by your entity of trust property of the trust?

See Practical Compliance Guideline PCG 2024/3 for more guidance.

Question 16

Has your entity excluded an amount that would otherwise have been assessable under subsection 99B(1) of the Income Tax Assessment Act 1936 through either the corpus or non-taxable exceptions?

See Practical Compliance Guideline PCG 2024/3 and Taxation Determination TD 2024/9 for more guidance.

Continue to: Section D: Declaration and signature – Super funds.

Return to: Section B: Category A and B reportable tax positions – Super funds.

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