Guide to completing Schedule 25A

Non-monetary consideration

A non-monetary consideration includes providing services, transferring tangible and intangible property or any similar dealings. The dealing may be a barter, swap, bonus or discount, or any type of similar agreement.

Monetary consideration will generally include:

• cash payments
• payment by cheque
• telegraphic and bank-to-bank transfer of funds
• inter-company loan account charges.

Non-monetary consideration therefore includes any consideration other than those involving the exchange of money or funds.

In particular, debt-for-equity swaps and non-monetary settlements of inter-company loan accounts are taken to be non-monetary consideration.

Example item 3a

Where there is no charge or adjustment allocating income or expenditure between the parties for provision of services, transfer of property, or other transactions listed on Schedule 25A by:

• the head office to the permanent establishment, or
• the permanent establishment to the head office or another related international party

this is regarded as being for nil consideration.

Example item 3b

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