What to disclose in Section B
In Section B, you need to disclose Category A and B reportable tax positions.
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 both 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, see Guide to understanding reportable tax positions.
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 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 question field – How many Category A and B reportable tax positions (RTPs) are you reporting?
RTP number
You must complete the RTP number field using the format:
- YYYY for the relevant income year for the RTP – for example, 2024
- follow the relevant income year with a dash (-)
- follow the dash with the number in the box beside the 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 2024–01, with each subsequent RTP numbered 2024–02, 2024–03.
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.
Select from the drop-down menu, either Yes or No.
You must complete all fields for each disclosure, no matter what answer you provide.
RTP category
Select from the drop-down menu the category of RTP you are reporting in the RTP category:
- A for Category A
- B for Category B
- A & B (for both categories).
Concise description
In the Concise description field, type a brief description of each Category A or B RTP. Briefly describe the arrangements or transactions, 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.
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 use 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.
In the PDF schedule, the Basis for position field accepts 3,000 characters or approximately 500 words. You can attach additional information if required.
Continue to: Section C: Category C reportable tax positions