The ATO advises that the schedule will apply to income years
starting on or after 1 July 2011.
This new disclosure obligation will mean that taxpayers will be
required to overly highlight their own tax exposures on an annual
basis – rather than the ATO requesting information on a
needs basis.
The ATO will provide a written notification to taxpayers who are
required to complete the schedule. It appears that the ATO
will roll out the schedule to the taxpayers in the "larger end
of town".
This will mean that affected taxpayers will have to identify any
reportable tax positions and disclose them to the ATO. The
ATO defines reportable positions to include:
- a material position that is more likely to be incorrect.
Presumably taxpayers will be exposed if they make an erroneous
assessment in relation to the degree of "correctness" in
relation to a particular tax position;