On 14 April 2024, the Australian Taxation Office (ATO) released the reportable tax position schedule 2024, which provides detailed guidance for filing returns.

According to the guidance, companies are obligated to file a completed reportable tax position schedule if their total business income for the current year reaches or exceeds AUD 250 million, or if total business income is AUD 25 million or more and the company is part of an economic group whose total business income meets or surpasses AUD 250 million.

This requirement also applies to companies that don’t even disclose their total business income. Additionally, the ATO can force companies to lodge a schedule regardless of whether these conditions are met per the guidance.

Who needs to complete the schedule?

You need to complete the schedule if your entity:

  • is lodging a company tax return for the entire year (12 months or more)
  • has a total business income of either
    • $250 million or more in the current year
    • $25 million or more in the current year and is part of an economic group with a total business income of $250 million or more in the current year.

If your entity meets the criteria, you need to lodge the RTP schedule 2024 even if it has no disclosures. You may still need to lodge the RTP schedule even if your entity doesn’t meet the criteria.

Exceptions to lodgment requirement

You are not required to lodge the schedule if your entity:

  • is not required to lodge a company tax return for the income year (the RTP schedule is a schedule to the company tax return)
  • has an income tax annual compliance arrangement (ACA) with us for the relevant income year and has agreed to provide
    • full and true disclosure
    • ongoing dialogue of all material tax matters, including positions that fall within any RTP category.

If you are uncertain if your entity is required to lodge the RTP schedule you can email to: reportabletaxposition@ato.gov.au.

Positions you need to disclose

You only need to disclose Category A positions that exceed your entity’s materiality amount. All Category C positions must be disclosed in the RTP schedule. If your entity is the head of a tax-consolidated group, you need to disclose positions that meet the requirements to be an RTP under categories A, B, and C for the head entity or any of its subsidiary group members.

What you must report on your entity’s tax return

If you are required to lodge an RTP schedule, you must answer Yes to item 25 of the Company tax return 2024.