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Reportable tax positions: A recent innovation by the ATO


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.

Author profile

Christopher Branson
Chris was admitted as Solicitor NSW September 1967 and admitted as Barrister NSW in August 1975. He was then appointed Queen’s Counsel and QC in all states and territories. Chris has practised as an advocate in NSW, ACT, WA and NT since 1975 and is currently the Deputy Chairman of the Law Council of Australia Taxation Subcommittee and is a Member of the Board of Taxation Advisory Panel. - Current at 01 February 2012
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