ATO extends RTP disclosure rules to large funds from July 2026

International businesses investing in Australia through fund structures will face expanded tax disclosure requirements from 1 July 2026, as the ATO introduces mandatory reportable tax position (RTP) schedules.

The RTP rules apply to large APRA-regulated super funds and collective investment vehicles (CIVs) with total fund or business income exceeding $250 million, provided they meet specific lodgment criteria. Affected entities must submit the RTP schedule alongside their annual income tax return, disclosing their most material and contestable tax positions. 

The measure brings these investment structures into closer alignment with existing corporate disclosure obligations, as part of the ATO’s broader effort to enhance transparency and strengthen oversight across high-value taxpayers. Separate RTP schedules have been developed for super funds and CIVs to reflect the distinct nature of these entities. 

For international businesses, the change is most relevant where Australian operations involve fund management, pooled investment structures, or CIVs. While standard trading subsidiaries are unlikely to be directly affected, global groups using Australian investment vehicles, or managing capital into Australia, may fall within scope if they meet the size and reporting thresholds. 

The ATO said the expanded regime is designed to promote consistency across taxpayer groups, improve its ability to detect and address tax risk, and support its ongoing “justified trust” programme. Increased disclosure is also expected to streamline engagement between the regulator and large institutional investors. 

Companies already required to lodge an RTP schedule will continue to do so without change, although their filing will now be referred to as the Company RTP schedule. 

The update signals a continued shift towards greater transparency and scrutiny of complex tax positions in Australia, particularly for large-scale investment structures used by international capital.

Last updated: 24th Apr 2026

About the Author

Ro Elvinia is ABN Australia's Customer Success and Marketing Manager. She holds a bachelor’s degree in mass communication, majoring in journalism, and also has an academic background in civil engineering. With over a decade of experience in professional writing and a background spanning journalism, Australian immigration, and business services, Ro brings a unique mix of communication and analytical expertise. She works closely with international clients and contributes to ABN Australia's content strategy, helping global businesses stay informed and confident as they navigate the Australian market.