Published on 01 Feb 12
by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE
The Australian Taxation Office (ATO) has recently added a powerful weapon to its arsenal of information-gathering procedures by requiring large corporations to make early disclosure of significant tax positions taken which may not be sustained when analysed at a later time.
This article considers the meaning of the core concepts relating to a reportable tax position (RTP), and problems relating to the application of those concepts from the perspective of the taxpayer and the revenue authority. The ATO initiative is based on, but materially different from, a regime introduced in the United States in 2010 by the Internal Revenue Service. The RTP regime has been introduced by the ATO as a pilot group program for the 2011 financial year, although important features remain unresolved.
Chris C BRANSON
Current at 29 August 2011
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