Changes to the Reportable Tax Position Schedule

Changes to the Reportable Tax Position Schedule

Ross Hocking explains the proposed changes to the Australian Taxation Office's Reportable Taxation Position Schedule.

Director, Tax Law

KPMG Australia


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The Reportable Taxation Position (RTP) Schedule pilot was introduced in 2011. Since then, all Q1 and Q2 taxpayers under the Risk Differentiation Framework as notified by the ATO, and that not do have an Annual Compliance Arrangement for income tax in place, have lodged an RTP as part of the pilot. 

The ATO has carried out targeted consultation, including a workshop with key tax advisors including KPMG and KPMG Law, as it plans for formalising the RTP schedule as business as usual and two tranches of changes to the RTP schedule. Specifics of the proposed changes have yet to be finalised, however, generally they are as follows:

Tranche 1

There will be an expansion of Category C to the RTP schedule for the 2017 income year and onwards. Category C, which currently requires disclosure of reportable transactions or events where certain large CGT events generate a significant book to tax difference, will be expanded to cover a broader range of tax risk areas that link back to an ATO view (Taxpayer Alerts, Public Rulings, cases etc.) through a simple yes/no disclosure response. The areas covered in Category C will also reflect tax risk in a more contemporaneous environment.

There will be no change to the current process for the selection of RTP taxpayers. 

Tranche 2

For the 2018 income year and onwards, the ATO proposes to expand the RTP population beyond the 80-90 higher consequence taxpayers to approximately 1,000 taxpayers in the large market. Relevant details are still in the early stages of consideration.

The RTP is no longer a pilot. It will become a permanent feature of how Public Groups and International (PGI) manage risk. The RTP will be one of a number of important risk tools used by PGI to ensure they have justified trust among the large market and to address situations where justified trust is absent.

We expect more specific information about the proposed changes to be available shortly. The expected completion date is November 2016.

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