Intangibles Migration Arrangements – Disclosure requirements for 2024 Reportable Tax Position Schedule

These new questions within the RTPS confirm the ATO’s continued focus on Intangibles Migration and DEMPE activities in light of transfer pricing and anti-avoidance considerations, as outlined by Sophie Lewis and Caleb Han.

The Australian Taxation Office (ATO), on 4 April 2024, published the 2024 Reportable Tax Position schedule (RTPS) instructions which are applicable for taxpayers lodging their 2023-2024 Income Tax Return (ITR), including taxpayers who have an early December balancing date (i.e. income years ended 31 December 2023). As a reminder, taxpayers are required to lodge a RTPS where total business income is either: $250 million or more in the current year; or $25 million or more in the curre...

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Authors: Sophie Lewis, Caleb Han

Published Date: 05 April 2024