• Category A: Tax uncertainty in your income tax return

    Attention

    Warning:

    This information may not apply to the current year. Check the content carefully to ensure it is applicable to your circumstances.

    End of attention

    A category A RTP is a position where it would be concluded in the circumstances, having regard to relevant authorities, that what is argued for is about as likely to be correct as incorrect, or is less likely to be correct than incorrect.

    Attention

    This does not include a position where you have exercised reasonable care and concluded in the circumstances, having regard to relevant authorities, that what is argued for is more likely to be correct than incorrect.

    End of attention

    Find out more

    For the purposes of the schedule, the phrases ‘about as likely to be correct as incorrect’, ‘more likely to be correct than incorrect’, and ‘relevant authorities’ take their meaning from MT 2008/2 Shortfall penalties: administrative penalty for taking a position that is not reasonably arguableExternal Link.

    End of find out more

    You must have regard to all matters relevant to the position – this includes anti-avoidance rules, integrity provisions, transfer pricing and market valuations.

    Danger

    You must disclose a material position that does not have regard to relevant authorities, or if there are none, that is not based on a well-reasoned construction of the applicable statutory provision. You must disclose such a material position even if it is based on administrative or industry practice.

    End of danger

    A category A RTP is material if the potential adjustment is equal to or exceeds your materiality amount. You only have to disclose a category A RTP if it is material.

    Last modified: 04 Jun 2014QC 40268