Work out how to complete each section in the RTP schedule and how to lodge.
Section A: Taxpayer details
Name of entity
The name entered on the schedule must be the same as shown on the company's tax return.
Tax file number (TFN)
The TFN entered on the schedule must be the same as shown on the company's tax return.
Australian business number (ABN)
The company's ABN entered on the schedule must be the same as shown on the company's tax return.
Period this schedule covers
Enter the period this schedule covers using DD/MM/YYYY format. This period is your entity's income year.
Section B: Category A and B reportable tax position (RTPs)
You need to disclose Category A and B RTPs in section B.
You only need to disclose Category A positions that exceed your entity's materiality amount.
You must confirm if your entity has any Category A or Category B disclosures.
Tax positions that are a Category C and Category A or B must be disclosed under section C. You must select No if your entity has an RTP that is both a Category C and Category A or B.
If you select No, go to Section C: Category C reportable tax positions.
If you select Yes, the next question will ask how many Category A or B RTPs you are reporting.
Category A: Tax uncertainty in your entity's company tax return
A Category A RTP is one where, given relevant authorities, you consider the position taken is either:
- about as likely to be correct as incorrect
- less likely to be correct than incorrect.
For more information refer to:
- Category A: Tax uncertainty in your tax return
- Category A and B positions relating to losses
- When a transfer pricing position is an RTP
- Disclosing RTPs on the schedule
Category B: Tax uncertainty in financial statements
You must disclose a position as a Category B RTP where your entity:
- prepares financial statements in accordance with the relevant accounting standards, including but not limited to applying AASB Interpretation 23 (PDF, 325KB)This link will download a file (Uncertainty over income tax treatments) in recognising, measuring and disclosing uncertain tax positions
- has recognised an uncertain tax position and/or disclosed a contingent liability for a position (asset) in its financial statements for the corresponding income year.
The concepts of recognition, measurement and disclosure are to be given meanings in accordance with accounting principles.
How many Category A and B RTPs are you reporting?
Enter the total number of RTPs you are reporting at the How many Category A and B reportable tax positions (RTPs) are you reporting? field.
Using the PDF schedule
In the PDF version, once you enter the number of RTPs you are disclosing and move off that field, it will automatically display the required number of fields needed to make the disclosure(s).
You must complete all mandatory fields for each RTP you are reporting.
RTP number
You must complete the RTP number field using the format:
- YYYY for the relevant income year for the RTP – for example, 2023
- followed by a dash (-)
- followed by the number corresponding to the number in the box beside RTP at the top of the section for that disclosure, placing a zero (0) before numbers less than 10.
There should be no spaces in the RTP number. Numbers should be sequential in the order you report the positions.
For example, number the first RTP 2023–01, with each subsequent RTP numbered 2023–02, 2023–03, and so on.
Have you discussed this position with the ATO?
For each disclosure, you must confirm if you (or another representative of your entity) have previously discussed the disclosure with us. All fields must be completed for each disclosure, no matter what answer you provide.
RTP category
Enter the category of RTP you are reporting in the RTP category:
- A for Category A
- B for Category B
- A & B (for both categories).
Using the PDF schedule
In the PDF version, select the appropriate category from the drop-down menu.
Concise description
Type a brief description of each Category A or B RTP in the Concise description field. Briefly describe the arrangement(s) or transaction(s), including the facts and circumstances, relevant to the position you are disclosing.
Positions covered by a private ruling
Where a position is covered by a private ruling, you only need to provide us with the reference number for the ruling in the Concise description field. This is also referred to as the authorisation number.
You can find the relevant reference number in the top right corner of correspondence from us.
Positions covered by an advance pricing arrangement application
A position subject to an advance pricing arrangement (APA) application must be disclosed if it meets the criteria for a Category A or B RTP. These positions must be disclosed even if the application has been accepted into our APA program.
For positions covered by an APA application, you only need to provide us with the APA application reference number in the Concise description field.
You can find the relevant reference number in the top right corner of APA application correspondence from us.
For examples, see Disclosing RTPs on the schedule.
Using the PDF schedule
Once information has been entered, the field will expand when you click another field. You will then be able to see all the information in the Concise description field.
Basis for position
Outline the position taken in your entity's tax return and the basis for that position, including:
- specific references in any legislation your entity relied on – don't just refer to a division or subdivision
- all relevant authorities you had regard to when concluding the likelihood of the position
- any industry or administrative practices.
If the position is covered by:
- a private ruling, type only private ruling in the Basis for position field, unless there are material differences in the implemented arrangement or transaction to what was described in the ruling – if material differences exist, you must state them in the Basis for position field
- a ruling application, which has been withdrawn, type only private ruling application - withdrawn in the Basis for position field
- an APA application, type only APA application in the Basis for position field.
For examples see Disclosing RTPs on the schedule.
Using the PDF schedule
Once information has been entered, the field will expand when you click on another field. You will then be able to view all the text within the Basis for position field.
The field accepts 3,000 characters or approximately 500 words. You can attach additional information if required.
Section C: Category C RTPs
You need to disclose Category C RTPs in section C.
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 covered is relevant for your entity.
Unless otherwise specified, the questions refer to arrangements or transactions:
- in place at any time in the income year
- covered by the tax return the schedule accompanies.
You don't need to disclose an arrangement for a Category C question referencing a taxpayer alert if:
- we have already reviewed the arrangement and advised 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 2022–23 income year?
You must confirm if your entity has any Category C disclosures.
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?
Enter the total number of Category C RTPs you are reporting.
You will 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.
You must complete all the mandatory fields for each RTP you are reporting.
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. All fields must be completed for each disclosure, no matter what answer you provide.
RTP Category C question and subcategory
Enter the number of the Category C question you are disclosing under 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.
Question 1
Question removed as the information is collected through other means.
Question 2
Did your entity fund a special dividend or a share buy-back through an equity raising event at a similar time, where the arrangement is a type, or variation, of an arrangement described in Taxpayer Alert TA 2015/2?
Question 3
Has your entity entered into an arrangement(s), or variation of an arrangement, described in Taxpayer Alert TA 2015/5 involving the use of offshore entities that source goods (procurement hubs)?
Question 4
Question removed due to impacts of legislative changes.
Question 5
Question removed as the information is collected through other means.
Question 6
Question removed as the arrangement falls within Schedule 2 of PCG 2017/4 and the risk rating under that schedule is required to be disclosed at question 23.
Question 7
If your entity entered into or varied any cross-border leasing arrangements involving the use, in Australian waters, of non-resident-owned mobile offshore drilling units (MODUs), disclose the outcome you have self-assessed using Practical Compliance Guideline PCG 2020/1.
- Subcategory 1: white zone
- Subcategory 2: green zone
- Subcategory 3: amber zone
- Subcategory 4: red zone
- Subcategory 5: if your entity's related party arrangement didn't involve the use, in Australian waters, of MODUs
- Subcategory 6: red zone, if you have not applied PCG 2020/1.
PCG 2020/1 outlines that MODUs include:
- drill-ships
- drilling rigs (including but not limited to submersibles, semi-submersible and jack-up rigs)
- pipe-laying vessels
- heavy-lift vessels.
Enter the relevant subcategory number in the RTP Category C subcategory field.
Question 8
Question removed due to impacts of legislative changes.
Question 9
If your entity has related party dealings involving a centralised services hub arrangement(s), disclose the outcome you have self-assessed using the applicable schedule in Practical Compliance Guideline PCG 2017/1 for each hub arrangement your entity is involved in.
For offshore marketing hub arrangements:
- 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, did not apply ATO risk methodology or calculate tax impact.
For offshore non-core procurement hub arrangements:
- 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, did not apply ATO risk methodology or calculate tax impact.
Enter the relevant subcategory number in the RTP Category C subcategory field.
In the comments section, provide the goods or commodities sourced from Australia and sold through the marketing hub arrangement, for each disclosed arrangement.
If the arrangement has been subject to any review by us, provide the Siebel reference number in the Comments field. This can be found in the top right corner of correspondence from us related to the review. It may also be referred to as our reference.
If the arrangement has been discussed with us, outside of a formal review product, provide details of the discussion in the Comments field.
Question 10
Has your entity excluded from its thin capitalisation calculations of debt capital any value of a debt interest that has been treated wholly, or partly, as equity under accounting standards?
Refer to Taxpayer Alert TA 2016/9 and Taxation Determination TD 2020/2 for more guidance.
Question 11
Is your entity currently involved in a cross-border, round robin financing arrangement(s) using an arrangement, or variation of an arrangement, described in Taxpayer Alert TA 2016/10?
Question 12
Was your entity party to an arrangement separating an integrated trading business into parts that results in trading income being re-characterised into more favourably taxed passive income?
Refer to Taxpayer Alert TA 2017/1 for more guidance.
Question 13
Has your entity claimed the R&D tax incentive using an arrangement, or variation of an arrangement, described in the subcategories below?
- Subcategory 1: Taxpayer Alert TA 2017/2 (construction activities)
- Subcategory 2: Taxpayer Alert TA 2017/3 (any business activities)
- Subcategory 3: Taxpayer Alert TA 2017/4 (agricultural activities)
- Subcategory 4: Taxpayer Alert TA 2017/5 (software development activities)
- Subcategory 5: More than one of the above taxpayer alert subcategories applies.
Enter the relevant subcategory number in the RTP Category C subcategory field.
If more than one taxpayer alert subcategory applies, enter the relevant taxpayer alerts in the Comments field.
Question 14
If your entity has a cross-border related party finance arrangement(s), disclose the outcome you have self-assessed using PCG 2017/4, 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.
Each arrangement must be included as a separate disclosure on the RTP schedule.
Materiality is determined by the loan amount in Australian dollar equivalent. It should be determined using the instructions to question 11 of the International dealings schedule.
For related party debt funding arrangements 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 have not applied Schedule 1.
For 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 have not applied Schedule 3.
Enter the relevant subcategory number in the RTP Category C subcategory field.
For each of the arrangements disclosed, provide 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.
Question 15
Question removed as the information is collected through other means.
Question 16
If your entity is an Australian income tax consolidated, or multiple entry consolidated (MEC) group, has it entered into any arrangement(s) where either of the following subcategories apply:
- Subcategory 1: the churning rule (in section 716-440 of the ITAA 1997) applies to deny certain cost setting rules
- Subcategory 2: the churning rule didn't apply because your entity didn't satisfy the test in paragraph 716-440(1)(f), as there is no change in the majority economic ownership of the joining entity within the 12-month period before the joining time.
Enter the relevant subcategory number in the RTP Category C subcategory field. Enter the number 1 if both subcategories apply where your entity has 2 separate positions.
If subcategory 2 applies to your entity's arrangement, in the Comments field provide details explaining how the arrangement didn't satisfy the test in paragraph 716-440(1) (f).
Question 17
At any stage during the income year, did your entity have a cross-border financing arrangement(s) with an international related party (including via back-to-back arrangements through third parties) where it claimed a tax deduction for interest, or an amount in the nature of interest, and interest withholding tax wasn't remitted because a withholding tax liability isn't expected to arise within the next 18 months.
Refer to Taxpayer Alert TA 2018/4 for more guidance.
Question 18
Question removed as the information is collected through other means.
Question 19
If your entity has reached a formal settlement agreement or future compliance arrangement with us that applies to the current income year, do either of the following subcategories apply:
- 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.
Enter the relevant subcategory number in the RTP Category C subcategory field. Enter the number 1 if both subcategories apply where your entity has 2 separate positions.
In the Comment field, provide the Siebel 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. It may also be referred to as our reference.
Question 20
Question removed as the information is collected through other means.
Question 21
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 all mistakes or omissions in that return are amended, 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 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 22
If your entity has restructured out of any arrangement(s) in the current year to which the hybrid mismatch rules applied, or would have applied had the arrangement(s) 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
- Subcategory 2 – one or more of the restructured arrangements don't qualify as low risk under Practical Compliance Guideline PCG 2018/7.
In considering whether the hybrid mismatch rules would apply you must disregard dual inclusion income.
Enter the relevant subcategory number in the RTP Category C subcategory field.
For arrangements that are not 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.
Question 23
If your entity has a related party derivative arrangement(s), disclose the outcome you have self-assessed using PCG 2017/4, Schedule 2 for the 3 most material arrangement(s).
If your entity has a related party derivative arrangement with a higher risk rating than the 3 already disclosed, you must also disclose this arrangement.
Each arrangement must be included as a separate disclosure on the RTP schedule.
Materiality is determined by the hedged item amount in Australian dollar equivalent.
- 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 have not applied Schedule 2.
Enter the relevant subcategory number in the RTP Category C subcategory field.
In the Comment field for each red and amber arrangement disclosed, provide the:
- underlying transaction hedged by the derivative, including the loan quantum in Australian dollar equivalent
- commercial and operational reasons for borrowing in a foreign currency
- name and location of the counterparty for the derivative and hedged item.
Question 24
If your entity has related party dealings involving an inbound distribution arrangement(s), in the RTP Category C subcategory field enter either:
- 9 where your entity hasn't self-assessed the risk zone of the arrangement(s) using PCG 2019/1
- If your entity has adopted the distributor simplified transfer pricing record keeping option in PCG 2017/2, record PCG 2017/2 applied in the Comments field.
- If paragraph 49 of PCG 2019/1 applies to your entity's arrangements, record in the Comments field which exclusion categories (from paragraph 49) apply.
- The appropriate number from the table below, where your entity has self-assessed the risk zone of the arrangement(s) using PCG 2019/1.
Category |
Low |
Medium |
High |
---|---|---|---|
General distributor – Schedule 1 (not in an industry sector specifically covered by a separate schedule) |
11 |
12 |
13 |
Category 1 Life science industry – Schedule 2 |
21 |
22 |
23 |
Category 2 Life science industry – Schedule 2 |
31 |
32 |
33 |
Category 3 Life science industry – Schedule 2 |
41 |
42 |
43 |
Category 1 ICT industry – Schedule 3 |
51 |
52 |
53 |
Category 2 ICT industry – Schedule 3 |
61 |
62 |
63 |
Motor vehicles industry – Schedule 4 |
71 |
72 |
73 |
Select the industry sector you believe best describes your entity. If the schedule for this industry sector has different categories of activities that generate value, select the one you believe best reflects the inbound distribution arrangement.
Calculate your entity's 5-year weighted average EBIT margin based on financial information without making adjustments for comparability purposes. This reflects how the profit markers in PCG 2019/1 have been constructed.
If your entity hasn't lodged tax returns for each of the 5 preceding income years, calculate the EBIT margin on a weighted average over the preceding years of consecutive lodgments.
If your entity has an inbound distribution arrangement but you can’t determine an EBIT margin for the arrangement, answer with Subcategory 9 indicating you did not apply PCG 2019/1. Provide the reason you couldn't determine the EBIT margin in the Comments field.
Question 25
Has your entity claimed deductions for expenses incurred under an arrangement(s) with offshore related or unrelated parties and used intangible assets held by an offshore party in connection with this arrangement(s), where the arrangement(s) doesn't appropriately recognise an amount as consideration for the use of the intangible assets.
Enter the number 1 in the RTP Category C subcategory field.
Has your entity claimed deductions for expenses incurred under an arrangement(s) with offshore related parties and used intangible assets held by an offshore related party in connection with this arrangement(s), 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 is not covered by section 284-255 (Taxation Administration Act 1953) compliant transfer pricing documentation.
Enter 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.
Refer to Taxpayer Alert TA 2018/2 for more guidance.
Question 26
If your entity is a multiple entry consolidated (MEC) group, has it entered into an arrangement(s), or variation of an arrangement, described in Taxpayer Alert TA 2019/1, where a group CGT asset (with a large unrealised capital gain) is sold through an eligible tier 1 company (with significant intra-group debt), which is subsequently sold to a third party who undertakes to extinguish the intra-group debt?
Question 27
Has your entity made a payment under a structured arrangement covered by item 1 of the table in subsection 832-615(2) of the Income Tax Assessment Act 1997?
Refer to LCR 2019/3 and PCG 2019/6 for more guidance.
In the Comments field, provide a description of the arrangement including the:
- name and place of incorporation or formation of the offshore deducting entity
- type of offshore hybrid arrangement and details of tax treatment of the parties to the arrangement in the relevant jurisdictions – for example, in the case of a reverse hybrid, provide the tax treatment for the offshore deducting entity, the reverse hybrid and any investing taxpayers
- amount of the offshore hybrid mismatch and the amount of deductions disallowed under section 832-610 for the structured arrangement.
Question 28
If your entity is a private company that is the head entity of a consolidated group, did any of the consolidated group members (including the head entity) make a loan to the head entity's shareholders or their associates that are external to the consolidated group where all of the following apply:
- the loan is not compliant with the terms of 109N
- the loan was not repaid by the lodgment date
- no statement has been provided to the recipient advising of a deemed dividend.
Refer to Taxation Determinations TD 2004/68 and TD 2018/13 for more guidance.
Question 29
Has your entity been part of an arrangement described by either:
- Subcategory 1 – Your entity has subscribed for a controlling share of units in a unit trust (where they did not 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 ITAA 1997, and where the unitholding(s) in the second trust has subsequently changed to the extent that it is no longer your associate?
Refer to Taxpayer Alert TA 2019/2 for more guidance.
Enter the relevant subcategory number in the RTP Category C subcategory field.
Enter the number 2 if both subcategories apply.
Question 30
If your entity is a private company and more than 10% of its issued shares are owned by a single shareholder acting as a trustee of a trust, do any of the subcategories below apply?
- Subcategory 1 – There was a change of trustee during the year that was not in connection with a trust split, or your entity does not know if there was a trust split.
- Subcategory 2 – There was a change of trustee during the year that was in connection with a trust split.
Refer to Taxation Determination TD 2019/14 for more guidance.
Enter the relevant subcategory number in the RTP Category C subcategory field.
Enter the number 2 if both subcategories apply.
Question 31
In the current, or 4 prior income years, has your entity, or an entity 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?
Refer to ATO Interpretative Decision ATO ID 2010/175 for more guidance.
Question 32
Has your entity entered into any arrangement(s), or variation of an arrangement, described in Taxpayer Alert TA 2020/1, involving non-recognition or mischaracterisation of Australian activities connected with the development, enhancement, maintenance, protection or exploitation (DEMPE) of intangible assets?
In the Comments field, provide a brief:
- description of the arrangements, outlining their legal form
- description of the intangible assets involved in any arrangements including the connected DEMPE activities
- explanation of the commercial and business rationale for entering into the arrangements.
Question 33
Has your entity entered into any arrangement(s) or scheme(s), or variation of an arrangement, described in Taxpayer Alert TA 2020/2, where the structure used by a foreign investor(s) to invest directly into an Australian business has been mischaracterised?
In the Comments field, provide:
- the foreign investor's identity
- a brief description of what features, if any, aren't consistent with vanilla debt or equity investments
- a brief explanation of how the investment provides the foreign investor with any direct exposure to the economic return from a particular business or assets exploited in the business.
Question 34
Has your entity entered into any arrangement(s), or variation of an arrangement with a non-resident related party, described in Taxpayer Alert TA 2020/3 and claimed a deduction for interest expenses under that arrangement ?
Question 35
Has your entity either:
- Subcategory 1: entered into an arrangement, or a variation of an arrangement, described in Taxpayer Alert TA 2020/4 involving the transfer of assets within a MEC group and an ET-1 company leaving the MEC group or an ET-1 company anticipated to the leave the MEC group in future?
- Subcategory 2: entered into an arrangement, or a variation of an arrangement, involving the transfer of assets within a MEC group and an ET-1 company leaving the MEC group or an ET-1 company anticipated to leave the MEC group in the future?
- Subcategory 3: entered into an arrangement where 1 or more companies became an ET-1 company and there was a transfer of assets to any of those ET-1 companies?
Question 36
Has your entity entered into any arrangement(s), or variation of an arrangement, described in Taxpayer Alert TA 2020/5 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 a derivative instrument(s)?
Question 37
If your entity is a non-ADI and has relied on the arm’s length debt test to determine its maximum allowable debt amount, disclose the outcome you have self-assessed using Practical Compliance Guideline PCG 2020/7.
Outward investing non-ADI:
- Subcategory 1: white zone
- Subcategory 2: low risk zone
- Subcategory 3: low to moderate risk zone
- Subcategory 4: medium risk zone
- Subcategory 5: high risk zone
- Subcategory 6: red zone, if you have not applied PCG 2020/7
Inward investing non-ADI:
- Subcategory 11: white zone
- Subcategory 12: low risk zone
- Subcategory 13: low to moderate risk zone
- Subcategory 14: medium risk zone
- Subcategory 15: high risk zone
- Subcategory 16: red zone, if you have not applied PCG 2020/7
Regulated utility, as defined in paragraphs 38 and 39 of PCG 2020/7:
- Subcategory 21: white zone
- Subcategory 22: low risk zone
- Subcategory 23: low to moderate risk zone
- Subcategory 24: medium risk zone
- Subcategory 25: high risk zone
- Subcategory 26: red zone, if you have not applied PCG 2020/7
Enter the relevant subcategory number in the RTP Category C subcategory field.
Question 38
Question has been removed.
Question 39
Has your entity made a payment to an entity that is a member of your entity's Division 832 control group(s) and that payment 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.
- 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: you red zone, if you have not applied PCG 2021/5.
Enter the relevant subcategory number in the RTP Category C subcategory field.
In the Comments field, provide:
- if the arrangement is rated red or amber, the reason the arrangement falls in that zone
- if subcategory 8 applies, the reason you didn't apply the PCG.
Question 40
Has your entity entered into any arrangement with a related overseas entity as described in Taxpayer Alert TA 2021/2 involving the inflow of funds to Australia as a gift or an advance of funds by way of a loan? If the advance of funds was by way of a loan, disclose the arrangement only where one or more of the following applies:
- there has been no repayment of the loan
- the repayments made were less than the interest incurred
- the loan has been refinanced to the same related overseas entity or an associate.
Question 41
During the year, did your entity:
- enter into an arrangement, or variation of an arrangement, as described in Taxpayer Alert TA 2022/2, and/or
- obtain a reduced withholding tax rate under one of Australia's double tax agreements in relation to royalty or unfranked dividend payments arising from an arrangement, or variation of an arrangement, described in TA 2022/2 entered into on or after 1 July 2021.
Question 42
Has your entity treated global intangible low-taxed income (GILTI) as 'subject to foreign income tax' in the United States under section 832-130 of the Income Tax Assessment Act 1997?
Refer to Taxation Determination TD 2022/9,for more guidance.
In the comments field please provide the:
- amount of GILTI your entity has used to reduce the amount of its deduction/non-inclusion mismatches
- amount of GILTI your entity has treated as dual inclusion income, and
- subsection of section 832-130 your entity treated GILTI as 'subject to foreign income tax' in the United States, subsection 832-130(5), subsection 832-130(1) or both.
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 briefly explain your entity's arrangements. Doing so may mean we:
- don't need to contact you for more information
- can ask more targeted questions if we do require more information.
Using the PDF schedule
The field accepts 3,000 characters or approximately 500 words. You can attach additional information if required.
Once information has been entered, the field will expand when you click on another field. You will then be able to see all the text in the Comments field.
Section D: Declaration and signature
Total number of pages being lodged
Type the total number of pages you are lodging including any attachments in Total number of pages being lodged.
Declaration
When the schedule is complete, the public officer must make a declaration that the information in the schedule and any attachments is true and correct.
To make the declaration:
- check the I declare that the information on this schedule is true and correct box.
In the declaration, include the:
- public officer's name and daytime phone number
- public officer's written or digital signature
- declaration date – on the PDF version, select the date in the drop-down box next to Date.
Signing the declaration
If you are lodging by mail the public officer must sign the printed schedule.
If you are lodging through Online services for business or Online services for agents, the public officer must check the I declare that the information on this schedule is true and correct box. They are not required to sign a printed copy and should lodge the electronic form (rather than a scanned version) via our online services.
How to lodge the schedule
You may be able to lodge the schedule as part of the tax return using the same SBR-enabled software you use to complete and lodge your entity's tax return.
Alternatively, if your software doesn't provide the schedule for electronic lodgment you can lodge through:
Online services
The best way to lodge is online as a mail message using Online services for business or Online services for agents:
- under Communication, select Secure Mail, select New
- Topic: Income tax
- Subject: RTP schedule lodgment
- write 20YY-YY RTP schedule in the message details (with the relevant financial year) to confirm the year the schedule relates to
- attach the schedule (maximum size is 6MB) and any attachments (maximum 6 files)
- check your message before sending to ensure the schedule and any attachments are attached
- send your mail message.
You will receive a confirmation and receipt number from us. Note the receipt number in case there are any issues. The message should remain in your sent items folder.
Mail your documents
Alternatively, you can print and post your completed schedule with any attachments to:
Australian Taxation Office
PO Box 9845
LOCALITY STATE POSTCODE
Don't use correction fluid or tape to make corrections to your completed schedule. If you make a mistake, make corrections electronically and print a new copy.