26 Aug 11 NTLG Working Group on Reportable Tax Positions
On Wednesday 24 August, Tax Counsel Deepti Paton ATIA attended a meeting of the NTLG Working Group on Reportable Tax Positions (RTPs). At this meeting, the ATO provided participants with an overview of the ATO’s progress on this project to date.
Participants discussed a number of issues, including:
- The ATO’s view on the concept of “materiality” when determining whether a tax position is required to be disclosed on the RTP schedule.
- The ATO’s work to date on the interaction between disclosure on the RTP schedule and legal professional privilege.
- The manner in which this project interacts with the ATO’s Risk Differentiation Framework for taxpayers.
- The manner in which the schedule will interact with Part IVA. The ATO expressed the view that reportable positions in relation to the application of Part IVA will need to be disclosed on the schedule.
The ATO has agreed to consider the manner in which the requirement to disclose on the schedule will interact with transfer pricing laws at a subsequent meeting of this Working Group.
Members who would like further information in relation to the above are encouraged to contact us at Tax Policy.