From Tax Time 2026, large APRA-regulated super funds and large collective investment vehicles (CIVs) with total fund/business income exceeding AUD 250 million will be required to lodge a reportable tax position (RTP) schedule, bringing their self-disclosure obligations in line with those of companies.
The Australian Taxation Office (ATO) announced on 21 April 2026 that from Tax Time (TT) 2026, reportable tax position (RTP) schedule obligations will apply to large APRA-regulated super funds and large collective investment vehicles (CIVs) that have:
- total fund/business income exceeding AUD 250 million, and
- meet the lodgment criteria set out in the relevant RTP schedule instructions.
A Fund RTP schedule and CIV RTP schedule have been developed, tailored for these respective entities. This inclusion aligns with a differentiated approach to obtaining justified trust for the superannuation and CIV industry, both for significant and general pool taxpayers.
By increasing the scope and regularity of self-disclosure obligations on large APRA-regulated super funds and large CIVs, the ATO can:
- promote a level playing field by ensuring super funds and CIVs have the same obligations as companies to disclose their most contestable and material tax positions
- improve focus on maintaining high levels of assurance and continue to detect and treat areas of low assurance
- continue to streamline the information gathering process and tailor engagement with taxpayers
- make informed decisions about future engagements with taxpayers.
For companies that already lodge an RTP schedule, this will now be called the Company RTP schedule; however, the obligation remains unchanged and lodgment should continue by the due date.
RTP schedules will be due with the relevant income tax return lodgment and will constitute an approved form.
