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2019 Reportable Tax Position lodgement requirements – what’s new?

2019 Reportable Tax Position lodgement requirements

Keith Swan, Matthew Hayes & Matthew McRae discuss the ATO's recently released reportable tax position schedule instructions for 2019.

Keith Swan

Partner, KPMG Law

KPMG Australia


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The release of the Australian Taxation Office’s (ATO) Reportable tax position schedule instructions 2019 on 20 May has been keenly awaited by those looking to understand the expanding scope of the RTP lodgement requirement.

The most significant change is that for tax years ending on or after 30 June 2019 taxpayers will not necessarily be notified of their obligation to lodge an RTP schedule. Rather, taxpayers are now required to self-assess against certain criteria in order to determine whether they are required to lodge an RTP schedule. As outlined below the criteria involve an expansion to the target taxpayer population that will have RTP reporting obligations.

The new RTP instructions also indicate there will be no new Category C questions that must be answered on the 2019 RTP schedule.

1. Affected taxpayers – have the RTP filing obligation thresholds changed in 2019?
As noted above, the major development for tax years ending on or after 30 June 2019 is taxpayers will be required to self-assess their RTP lodgement obligation. This has will likely result in an expansion of the taxpayer population affected.

An RTP schedule now needs to be filed by:

  • every company notified in writing of its requirement to do so (NB: KPMG is now expecting the ATO will only adopt this notification process for a very small group of companies); and
  • every public company or a foreign-owned company that:
    has total business income of $250 million or more in the current year, or
  • has total business income of $25 million or more in the current year and is part of a public or foreign owned economic group whose total business income is $250 million or more in the current year or the immediate prior year.

The ATO’s definition of an “economic group” includes all entities (i.e. companies, trusts, partnerships etc.) under an ultimate holding company or ultimately owned by an individual, trust or partnership. The total income of the economic group is the sum of 'total income' labels reported in the relevant tax returns. This includes all Australian sourced income and foreign income of Australian resident entities but does not include foreign income of foreign entities.

To read more on 2019 Reportable Tax position lodgement requirements, please log on to KPMG Tax Now.

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