Guide to completing Schedule 25A

Related-party international dealings

Related-party international dealings means international transactions, agreements or arrangements between related parties, or between a permanent establishment and its head office, or between two permanent establishments of the same entity. The term includes all transactions between an Australian resident and international related parties.

If money or property is not actually sent out of Australia or received in Australia, but accounting entries are made that have a similar effect to money or property being transferred, this is also taken to be an international transaction.

Sections within Definition glossary

• Permanent establishment or branch
• International related parties
• Central management and control
• Participates in capital
• Relationship
• Transactions
• Related-party international dealings
• Tangible property
• Intangible property
• Services
• Other transactions
• Aggregate amount
• Total dollar value
• Non-monetary consideration
• Arm's length principle
• Transfer pricing
• Arm's length pricing methods
• Arm's length pricing codes and methodology
• Documentation
• Pricing methods for capital assets
• Listed and unlisted countries
• Controlled foreign company
• Controlled foreign entity
• Controlled foreign partnership
• Controlled foreign trust
• Eligible transferor
• Attributable taxpayer
• Attributable income
• Tainted income
• Active income test
• Eligible designated concession income
• Tainted assets
• Non-portfolio dividends
• Foreign investment fund
• Foreign life insurance policy
• Attribution account
• Subdivision 768-G of ITAA 1997
• Underlying active business
• Extent of the reduction
• Foreign company assets
• Non-resident trust estate
• Entitled to acquire
• Attribution percent x adjusted distributable profits
• Attribution percent x interest/entitlement x section 456 to 459A amount
• Discretionary trust estate
• Control in relation to a trust estate
• Notional accounting period
• Interests in a foreign investment fund or foreign life policy
• What income has been comparably taxed?
• Non-assessable non-exempt income
• Controlled foreign company rules
• Foreign investment fund rules
• Transferor trust rules
• Foreign company
• Foreign trust
• Change of residence of a controlled foreign company from an unlisted country to Australia
• Change of residence of a controlled foreign company from an unlisted country to a listed country