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  • Country-by-Country reporting: local file / master file detailed design

    This guidance builds on the local file – high level design by providing an overview of the detailed design of the local file / master file. It reflects underlying IT specifications (contained in the XML schema) for digital service providers to use in business management software to enable generation of a valid XML file.

    We have developed a combined local file / master file XML schema, so the master file must be attached to the combined submission. As previously communicated, we have adopted Annex I of the OECD guidanceExternal Link as the information requirements for the master file.

    The local file / master file XML schema comprises:

    The design of the local file / master file XML schema allows for separate submissions of the three components of the local file (ie short form, Part A and Part B) and the master file.

    While the local/master file XML schema contains questions in relation to your lodgment of the Country-by-Country (CbC) report, the CbC report itself must be lodged separately in accordance with the OECD XML schemaExternal Link (v1.0).

    You should also refer to the Appendixes for various relevant codes used for reporting as part of the lodgment.

    See also:

    Electronic lodgment

    CbC statements (the CbC report, master file and local file) must be lodged via one of the following ATO approved channels:

    Paper lodgments of CbC statements will not be accepted. For more information on electronic lodgment, visit our Online Services page. For more information on the XML schema, visit our Significant Global Entity ObligationExternal Link (SGEO) page on the SBR websiteExternal Link.

    Attachments

    Naming convention

    To facilitate the provision of attachments, the following naming convention for attachments must be used: <Reporting Year>_<Statement Type>_<Transaction ID>_<Version>_<Name>.<ext>.

    Where <Reporting Year> is mandatory and in the form of 'YYYY'.

    Where <Statement Type> is mandatory and must be one of the following values:

    • 'MSTR' for master file
    • 'LFSF' for local file – short form
    • 'LFPBI' for IRP agreement
    • 'LFPBA' for Advance Pricing Arrangement
    • 'LFPBR' for Ruling
    • 'LFPBF' for financial accounts
    • 'LFPBO' for other

    If the <Statement Type> is 'LFPBI', 'LFPBA' or 'LFPBR' the <Transaction ID> element is mandatory.

    <Version> is mandatory and must be one of the following values:

    • 'A' for amended, or
    • 'O' for original

    <Name> is mandatory and can be chosen by the reporting entity.

    <ext> is mandatory and can only be one of those listed in the Attachment types section below.

    The filename cannot exceed 255 characters. This filename is reflected within the XML file.

    Duplicate attachments

    Where an IRP agreement relates to multiple transactions, it needs to be provided only once (ie for the first transaction that relates to that agreement). Where a transaction is reported in relation to that IRP agreement, at Question ID LCMSF54, the filename of the IRP agreement (following the naming convention above) must be provided.

    In the case of amended IRP agreements, the above also applies, with the exception that the filename (following the naming convention above) must be provided at Question ID LCMSF132.

    Where an APA / ruling relates to multiple transactions, the APA/ruling needs to only be provided once (ie for the first transaction that relates to that APA/ruling). Where a transaction is reported in relation to that APA/ruling, at Question ID LCMSF136, the filename of the APA / ruling (following the naming convention above) must be provided.

    Attachment types

    Table 1: Supported attachment types / formats

    File Extension

    File type

    DOC

    Microsoft Word Binary File Format

    DOCX

    Office Open XML

    XLS

    Excel Binary File Format

    XLSX

    Office Open XML

    PDF

    Portable Document Format

    ODT

    OpenDocument Text

    ODS

    OpenDocument Spreadsheet

    Message structure table

    The following tables provide an overview of the local / master file XML schema. The question IDs relate to the associated elements provided in the message structure tableExternal Link (MST) provided to digital service providers.

    Statement information

    This section must always be completed for every submission.

    Table 2: Statement information

    Question

    Question ID

    Valid values

    Comments

    Amendment

    LCMSF1

    True/False

    Mandatory question

    Indicates whether this lodgment is an amendment to a previous lodgment

    Amended lodgments do not include those where additional statements (or parts thereof) are being provided for the first time

    Reporting period start date

    LCMSF142

    YYYY–MM–DD

    Mandatory question

    The start date of the tax year of the reporting entity

    Reporting period end date

    LCMSF143

    YYYY–MM–DD

    Mandatory question

    The end date of the tax year of the reporting entity

    Intermediary information

    This section is only required if the form is submitted by an intermediary on behalf of the reporting entity.

    Table 3: Intermediary information

    Question

    Question ID

    Valid values

    Comments

    Intermediary ABN

    LCMSF2

    ABN

    Must be a valid ABN

    Intermediary name

    LCMSF3

    Name of the intermediary

    Maximum of 200 characters

    Intermediary email

    LCMSF4

    Email address

    Maximum of 200 characters

    Intermediary phone

    LCMSF5

    Mobile or landline

    Maximum of 16 characters

    Tax Agent Number (TAN)

    LCMSF6

    TAN

    Must be a valid TAN

    Entity information

    Reporting entity information

    Table 4: Reporting entity information

    Question

    Question ID

    Valid values

    Comments

    Reporting Entity ABN

    LCMSF7

    ABN

    Either an ABN or TFN is required

    Reporting Entity TFN

    LCMSF65

    TFN

    Reporting Entity name

    LCMSF8

    Legal name of the entity

    Mandatory question

    Maximum of 200 characters

    Reporting Entity email

    LCMSF21

    Email address

    Mandatory question

    Maximum of 200 characters

    Reporting Entity phone

    LCMSF22

    Mobile or landline

    Mandatory question

    Maximum of 16 characters

    Is the Reporting Entity the head entity of a tax consolidated group?

    LCMSF15

    True/False

    Mandatory question

    Is the Reporting Entity the provisional head entity of a Multiple Entry Consolidated (MEC) group?

    LCMSF16

    True/False

    Mandatory question

    Are there other Australian resident taxpayers in your accounting group (but not in your tax consolidated group)?

    LCMSF17

    True/False

    Mandatory question

    Is the Reporting Entity an Offshore Banking Unit (OBU)?

    LCMSF61

    True/False

    Mandatory question

    Global parent entity information

    Table 5: Global parent entity information

    Question

    Question ID

    Valid values

    Comments

    Are you a global parent entity?

    LCMSF66

    True/False

    Mandatory question

    If True, go to Statement Lodgment Criteria section

    Global parent entity name

    LCMSF11

    Legal name of the entity

    Maximum of 200 characters

    Global parent entity tax jurisdiction

    LCMSF12

    Country Code

    If the Country Code is AU (ie Australia), either an ABN or TFN is required

    Global parent entity ABN

    LCMSF9

    ABN

    Either an ABN or TFN is required

    Global parent entity TFN

    LCMSF10

    TFN

    Statement lodgment criteria

    Local file

    Table 6: Local file lodgment criteria

    Question

    Question ID

    Valid values

    Comments

    Will this submission include details on your lodgment of the local file?

    LCMSF137

    True/False

    Mandatory question

    If False, go to Master File section

    Has the Commissioner, by notice in writing, exempted you from providing the local file for this reporting period?

    LCMSF117

    True/False

    If True, go to Master File section

    Are you lodging any part of the local file in this submission?

    LCMSF118

    True/False

    If False, go to Master File section

    Which parts of the local file are you lodging in this submission?

    LCMSF119

    Local file – short form, Local file – Part A, Local file – Part B

    Multiple values can be selected, which form the parts of the Local File

    Is your lodgment of Part A of the local file (part of the 'Administrative Solution')?

    LCMSF68

    True/False

    Administrative Solution

    Have you been granted a replacement reporting period for the local file?

    LCMSF120

    True/False

    If True, replacement reporting period dates must be provided

    Replacement reporting period start date

    LCMSF13

    YYYY–MM–DD

    The start date of the replacement reporting period

    Replacement reporting period end date

    LCMSF14

    YYYY–MM–DD

    The end date of the replacement reporting period

    Local file – short form

    Table 7: Local file – short form lodgment criteria

    Question

    Question ID

    Valid values

    Comments

    Did you engage in IRP transactions or dealings listed on the short form exceptions list for the reporting period?

    LCMSF27

    True/False

    Mandatory question

    If True go to Master File section

    Did you have less than $2m in aggregate IRPDs for the reporting period?

    LCMSF28

    True/False

    IRPDs are as defined in the IDS.

    Did you meet the criteria for the 'Small Taxpayers' STPRK option for the reporting period?

    LCMSF29

    True/False

    'Small Taxpayers' STPRK option

    Did you meet the criteria for the 'Materiality' STPRK option for the reporting period?

    LCMSF30

    True/False

    'Materiality' STPRK option

    Master file

    Table 8: Master file lodgment criteria

    Question

    Question ID

    Valid values

    Comments

    Will this submission include details on your lodgment of the master file?

    LCMSF138

    True/False

    Mandatory question

    If False, go to CbC Report section

    Has the Commissioner, by notice in writing, exempted you from providing the master file for this reporting period?

    LCMSF81

    True/False

    If True, go to CbC Report section

    Are you lodging the master file as part of this submission?

    LCMSF75

    True/False

    Select False if the master file will be lodged by another entity on your behalf or if you are applying the Administrative Concession 

    Have you been granted a replacement reporting period for the master file?

    LCMSF121

    True/False

    Mandatory question

    If True, replacement reporting period dates must be provided

    Replacement reporting period start date

    LCMSF122

    YYYY–MM–DD

    The start date of the replacement reporting period

    Replacement reporting period end date

    LCMSF123

    YYYY–MM–DD

    The end date of the replacement reporting period

    Is your lodgment of the master file also on behalf of other entities in your Australian accounting group?

    LCMSF76

    True/False

    If True, a valid ABN or TFN must be provided

    ABN(s) of the entities

    LCMSF19

    ABN

    Either valid ABN(s) or TFN(s) must be provided

    TFN(s) of the entities

    LCMSF20

    TFN

    Please confirm that you have attached the master file

    LCMSF124

    True/False

    The master file should meet the information requirements as outlined in Annex I of the OECD GuidanceExternal Link

    Will another entity in your Australian accounting group be lodging the master file (on your behalf)?

    LCMSF79

    True/False

    If True, a valid ABN or TFN must be provided

    ABN of the entity

    LCMSF19

    ABN

    Either the ABN or TFN is required

    TFN of the entity

    LCMSF20

    TFN

    Is any foreign entity in your global accounting group required to prepare or file a master file in another country by the time your master file is due for lodgment in Australia?

    LCMSF93

    True/False

    LCMSF93 must be False and LCMSF108 must be True to take advantage of the Administrative Concession in relation to the Master File for the first reporting period

    Do you commit to provide (or ensuring another entity in your Australian accounting group provides) the master file for the second reporting period starting on or after 1 January 2017?

    LCMSF108

    True/False

    On the basis of your circumstances and commitment to filing the master file for the second reporting period, the Commissioner will not require the master file for the first reporting period. Please provide the entity’s ABN(s) to be covered by this concession

    LCMSF109

    True/False

    Either valid ABN(s) or TFN(s) must be provided.

    On the basis of your circumstances and commitment to filing the master file for the second reporting period, the Commissioner will not require the master file for the first reporting period. Please provide the entity’s TFN(s) to be covered by this concession

    LCMSF110

    True/False

    CbC report

    Table 9: CbC report lodgment criteria

    Question

    Question ID

    Valid values

    Comments

    Will this submission include details on your lodgment of the CbC report?

    LCMSF139

    True/False

    Mandatory question

    If False, go to Local File section.

    Has the Commissioner, by notice in writing, exempted you from providing the CbC report for this reporting period?

    LCMSF69

    True/False

    If True, a valid ABN or TFN must be provided

    ABN(s) of the entities

    LCMSF111

    ABN

    Either valid ABN(s) or TFN(s) must be provided

    TFN(s) of the entities

    LCMSF112

    TFN

    Have you been granted a replacement reporting period for the CbC report?

    LCMSF125

    True/False

    If True, replacement reporting period dates must be provided

    Replacement reporting period start date

    LCMSF126

    YYYY–MM–DD

    The start date of the replacement reporting period

    Replacement reporting period end date

    LCMSF127

    YYYY–MM–DD

    The end date of the replacement reporting period

    Is the lodgment of the CbC report also on behalf of other entities in your Australian accounting group?

    LCMSF114

    True/False

    If True, ABN or TFN must be provided

    ABN(s) of the entities

    LCMSF115

    ABN

    Either valid ABN(s) or TFN(s) must be provided

    TFN(s) of the entities

    LCMSF116

    TFN

    Has / will an entity in your global accounting group file a CbC report in another jurisdiction for this reporting period where that report will be automatically exchanged with Australia?

    LCMSF70

    True/False

    If True, name and tax jurisdiction must be provided

    What is the name of the entity?

    LCMSF71

    Legal name of the entity

    Maximum of 200 characters

    What is the tax jurisdiction of the entity?

    LCMSF74

    Country Code

     

    Will another entity in your Australian accounting group be lodging the CbC report for this reporting period (on your behalf)?

    LCMSF26

    True/False

    If True, a valid ABN or TFN must be provided

    ABN of the entity

    LCMSF72

    ABN

    Either a valid ABN or TFN must be provided

    TFN of the entity

    LCMSF73

    TFN

    Are you filing the CbC report as a surrogate parent entity with the filing intended to meet a CbC reporting obligation in other jurisdiction(s)?

    LCMSF140

    True/False

     

    Please confirm that you will be lodging a CbC report for this reporting period

    LCMSF141

    True/False

    The CbC report must be lodged separately in accordance with the OECD XML schemaExternal Link

    Local file

    Local file – short form

    This section is required if you have selected that you will be providing the local file – short form as part of this submission in Question ID LCMSF119 (in the statement lodgment criteria section).

    Table 10: Local file – short form

    Question

    Question ID

    Valid values

    Comments

    Please confirm that you have attached the local file – short form

    LCMSF82

    True/False

    Required if LCMSF119 indicates that the short form is being lodged

    Local file – Part A

    This section is required if you have selected that you will be providing the local file – Part A as part of this submission in Question ID LCMSF119 (in the Statement lodgment criteria section).

    Table 11: Local file – Part A

    Question

    Question ID

    Valid values

    Comments

    Local file – Part A Transaction Identifier

    LCMSF31

    Number

    Mandatory question

    Incrementing number for each transaction that is used to link Part A, Part B and the related IRP agreement and APA/ruling

    Transaction type

    LCMSF32

    Transaction Category

    Mandatory question

    See Appendix C

    Is this transaction part of a Relevant Agreement Series (RAS) as defined?

    LCMSF33

    True/False

    Mandatory question

    See Local file – Part B: Guidance on providing International Related Party agreements

    How many transactions are part of the Relevant Agreement Series?

    LCMSF35

    Low/Moderate/High

    Low = 1–5
    Moderate = 6–50
    High = 50 or more

    ABN of the Australian counterparty to the transaction

    LCMSF83

    ABN

    Either the ABN or TFN is required

    TFN of the Australian counterparty to the transaction

    LCMSF84

    TFN

    Name of the non-resident counterparty/ies to the transaction

    LCMSF37

    Legal name of the entity

    Mandatory question

    Maximum of 200 characters

    Tax residence of non-resident counterparty/ies to the transaction

    LCMSF38

    Country Code

    Mandatory question

    Amount of consideration paid (of a capital nature for income tax purposes) for the transaction

    LCMSF39

    $XX,XXX,XXX,XXX

    Mandatory question

    Amount of consideration received (of a capital nature for income tax purposes) for the transaction

    LCMSF40

    $XX,XXX,XXX,XXX

    Mandatory question

    Was non-monetary consideration provided (of a capital nature for income tax purposes) for the transaction?

    LCMSF85

    True/False

    Mandatory question

    Was non-monetary consideration obtained (of a capital nature for income tax purposes) for the transaction?

    LCMSF86

    True/False

    Mandatory question

    Amount of expenditure (not of a capital nature for income tax purposes) for the transaction

    LCMSF41

    $XX,XXX,XXX,XXX

    Mandatory question

    Amount of revenue (not of a capital nature for income tax purposes) for the transaction

    LCMSF42

    $XX,XXX,XXX,XXX

    Mandatory question

    Was non-monetary consideration provided (not of a capital nature for income tax purposes) for the transaction

    LCMSF44

    True/False

    Mandatory question

    Was non-monetary consideration obtained (not of a capital nature for income tax purposes) for the transaction

    LCMSF45

    True/False

    Mandatory question

    Amount of foreign exchange losses deducted for the transaction

    LCMSF87

    $XX,XXX,XXX,XXX

    Mandatory question

    Amount of foreign exchange gains returned for the transaction

    LCMSF43

    $XX,XXX,XXX,XXX

    Mandatory question

    What transfer pricing / capital asset pricing methodology has been applied to this transaction?

    LCMSF46

    TP Method / CAP Method

    Mandatory question

    See Appendix B

    What level of transfer pricing documentation has been prepared for this transaction?

    LCMSF47

    TP Documentation Codes / STPRK Options

    Mandatory question

    Both TP Documentation Codes and STPRK values can be provided

    See Appendix A

    Has the special short term tenor rule for ordinary borrowings and ordinary loans been applied to this transaction?

    LCMSF88

    True/False

    Mandatory question

    Has the special short term tenor rule for short term derivatives been applied to this transaction?

    LCMSF128

    True/False

    Mandatory question

    Has the special short term tenor rule for FX derivatives been applied to this transaction?

    LCMSF129

    True/False

    Mandatory question

    Is this transaction an OB Activity?

    LCMSF63

    True/False

     

    Is this transaction covered by a category on the exclusions list?

    LCMSF48

    True/False

    Mandatory question

    What category of the exclusion list applies to this transaction?

    LCMSF49

    Exclusion List Category

    See Appendix D

    Local file – Part B

    This section is required if you have selected that you will be providing the local file – Part B as part of this submission in Question ID LCMSF119 (in the statement lodgment criteria section).

    For more information on providing International Related Party (IRP) agreements in local file – Part B see: Local file – Part B: Guidance on providing International Related Party agreements.

    Table 12: Local file – Part B

    Question

    Question ID

    Valid values

    Comments

    Local file – Part A Transaction Identifier

    LCMSF50

    Number

    Mandatory question

    Incrementing number for each transaction that is used to link Part A, Part B and the related IRP agreement and APA / ruling

    Which transfer pricing / capital asset methodology has the IRP relied upon for this transaction?

    LCMSF51

    TP Method / CAP Method

    Mandatory question

    See Appendix B

    Is the Reporting Entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction?

    LCMSF130

    True/False

    Required if LCMSF51 is 'Unknown (TP Method)' or 'Unknown (CAP Method)'

    Is there a written agreement or other relevant documentation evidencing the terms of the agreement covering this transaction (as reported in Part A)?

    LCMSF52

    True/False

    Mandatory question

    Is the Reporting Entity able to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction (as reported at Part A)?

    LCMSF64

    True/False

    Required if LCMSF52 is False

    Has this written agreement been previously provided to the ATO?

    LCMSF53

    True/False

    Required if LCMSF52 or LCMSF64 is True

    Where an agreement relates to multiple transactions, the agreement only needs to be provided once

    Where a subsequent transaction has the same agreement as another (which has already been provided) in this submission then this should be answered True

    Please confirm that you have attached the agreement(s) for this transaction

    LCMSF89

    True/False

    Required if LCMSF53 is False

    Title of the agreement previously provided to the ATO

    LCMSF54

    Title of the IRP Agreement

    Required if LCMSF53 is True

    In cases where the agreement has been previously provided in the same submission but for a different transaction, please provide the Document ID in this field.

    What is the year in which the agreement was previously provided to the ATO?

    LCMSF90

    YYYY

    Required if LCMSF53 is True

    In cases where the agreement has been previously provided in the same submission but for a different transaction, please provide the <Reporting Year> as used in the filename for the agreement

    Since providing the written agreement to the ATO, has the agreement been amended?

    LCMSF91

    True/False

    Required if LCMSF53 is True

    Have the amended agreements or agreements incorporating the amendments been provided to the ATO?

    LCMSF92

    True/False

    Required if LCMSF91 is True

    Please confirm that you have attached the amendments for previously provided agreements for this transaction

    LCMSF131

    True/False

    Required if LCMSF92 is False

    What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

    LCMSF132

    Title of the IRP Agreement (Amendment)

    Required if LCMSF92 is True

    What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

    LCMSF133

    YYYY

    Required if LCMSF92 is True

    Are there APAs/rulings provided by other jurisdictions for this transaction?

    LCMSF106

    True/False

    Mandatory question

    Has the Reporting Entity previously provided these APAs / rulings to the ATO?

    LCMSF134

    True/False

    Required if LCMSF106 is True

    Please confirm that you have attached the relevant APAs/rulings for this transaction

    LCMSF135

    True/False

    Required if LCMSF134 is False

    What is the year in which the Reporting Entity previously provided these APAs/rulings?

    LCMSF136

    YYYY

    Required if LCMSF134 is True

    Please confirm that you have attached the Reporting Entity’s financial accounts for the reporting period

    LCMSF107

    True/False

    Mandatory question

    Declarations

    Reporting entity declaration

    Required if the statement is submitted by the reporting entity.

    Table 13: Reporting entity declaration

    Question

    Question ID

    Valid values

    Comments

    Reporting Entity declaration statement accepted indicator

    LCMSF55

    True/False

     

    Reporting Entity declaration signature date

    LCMSF56

    YYYY–MM–DD

    The actual date on which the declaration is signed by the reporting entity

    Reporting Entity declaration signatory identifier

    LCMSF57

    A user login, a full name or an email address

    Maximum of 200 characters

    Intermediary declaration

    Required if the statement is submitted by an intermediary.

    Table 14: Intermediary declaration

    Question

    Question ID

    Valid values

    Comments

    Intermediary declaration statement accepted indicator

    LCMSF58

    True/False

     

    Intermediary declaration signature date

    LCMSF59

    YYYY–MM–DD

    The actual date on which the declaration is signed by the intermediary

    Intermediary declaration signatory identifier

    LCMSF60

    A user login, a full name or an email address

    Maximum of 200 characters

    Appendixes

    Appendix A: TP documentation codes / STPRK options

    Table 15: Appendix A

    Code

    Value

    1

    0%

    2

    1% to less than 25%

    3

    25% to less than 50%

    4

    50% to less than 75%

    5

    75% to less than 100%

    6

    100%

    7

    Simplified Transfer Pricing Record Keeping (Materiality)

    8

    Simplified Transfer Pricing Record Keeping (Small Taxpayers)

    9

    Simplified Transfer Pricing Record Keeping (Distributors)

    10

    Simplified Transfer Pricing Record Keeping (Intra-Group Services)

    11

    Simplified Transfer Pricing Record Keeping (Management & Administration Services)

    12

    Simplified Transfer Pricing Record Keeping (Technical Services)

    13

    Simplified Transfer Pricing Record Keeping (Low Level Loans – Inbound)

    14

    Simplified Transfer Pricing Record Keeping (Low Level Loans – Outbound)

    Appendix B: TP method / CAP method

    Table 16: Appendix B

    Code

    Value

    APPC

    Apportionment of costs

    APPI

    Apportionment of Income

    CUP

    Comparable uncontrolled price method

    CCA

    Cost-contribution arrangement

    CP

    Cost-plus method

    FMUAC

    Fixed mark-up applied to cost

    FPRP

    Fixed percentage of resale price

    MC

    Marginal costing

    PS

    Profit split method

    RPM

    Resale price method

    TNM

    Transactional net margin method

    TNMW

    Transactional net margin method (whole-of-entity)

    OTH

    Other arm's length methods

    NON

    None

    UNKT

    Unknown (Transfer Pricing Method)

    CPR

    Cost Price

    DVAL

    Directors valuation

    DCF

    Discounted cash flow

    IVAL

    Independent valuation

    NCON

    Nil consideration

    QMRP

    Quoted market price

    WDVAL

    Written-down Value

    OM

    Other methods

    UNKC

    Unknown (Capital Asset Pricing Method)

    Appendix C: Transaction categories

    Table 17: Appendix C

    Code

    Value

    TPRN

    Tangible property of a revenue nature

    RUIP

    Rights to use IP

    ORSR

    Other rights to use, supply or receive where consideration is royalty under section 6(1) of the ITAA 1936

    LF

    Licence fees

    RRP

    Rent of real property

    HLPE

    Hire or lease of plant or equipment

    LHORP

    Lease or hire of other property or rights

    TRS

    Treasury related services

    MAS

    Management and admin services

    INSERV

    Insurance services

    REINSERV

    Reinsurance services

    RD

    Research and development

    SAM

    Sales and marketing

    SITS

    Software and IT services

    TS

    Technical services

    LS

    Logistics

    AM

    Asset Management

    OS

    Other services

    CCIRS

    Cross currency interest rate swap

    CDCSFFO

    Currency derivative (not cross currency interest rate swap), including currency swap, forward, future or option

    FFIRS

    Fixed for floating interest rate swap (not cross currency)

    OIRD

    Other interest rate derivative (not cross currency)

    CDS

    Credit default swap

    AS

    Asset swap

    CDCS

    Commodity derivative, including commodity swap, forward, future or option

    OD

    Other derivative

    IDF

    Inward debt factoring

    ODF

    Outward debt factoring

    IDSEC

    Inward debt securitisation

    ODSEC

    Outward debt securitisation

    OBL

    Ordinary borrowings / loans (excluding trade financing)

    TFIN

    Trade financing

    BND

    Bonds

    PNOT

    Promissory notes

    CNTDI

    Convertible notes that are debt Interests

    CSTDI

    Convertible shares that are debt Interests

    RPSDI

    Redeemable preference shares that are debt Interests

    OKDI

    Other kinds of debt Interests

    IORDI

    Interest or other return on debt Interest

    GILDI

    Guarantee or indemnity of liability under debt Interest

    GIOKL

    Guarantee or indemnity of other kind of liability

    IN

    Insurance

    REIN

    Reinsurance

    OFD

    Other financial dealings

    ORIRPD

    Other revenue IRPDs

    RPRT

    Real property

    PLEQ

    Plant or equipment

    OTPRTY

    Other tangible property

    ASIP

    Assignment of IP

    IOSH

    Issue of ordinary shares

    AOSH

    Assignment of ordinary shares

    IEIOOS

    Issue of equity interest other than ordinary shares

    AQIOS

    Assignment of equity interest other than ordinary Shares

    ASSD

    Assignment of debts

    ASSL

    Assignment of liabilities

    ASSBC

    Assignment of benefit of contracts (excluding assignment of equity interests, debts or IP)

    ASSOPR

    Assignment of other intangible property or rights

    SBER

    Share based employment remuneration

    CCA

    Cost contribution arrangement

    Appendix D: Exclusion list

    Table 18: Appendix D

    Code

    Value

    STPRKIGS

    Simplified Transfer Pricing Record Keeping (Intra-Group Services)

    STPRKMAS

    Simplified Transfer Pricing Record Keeping (Management & Administration Services)

    STPRKTS

    Simplified Transfer Pricing Record Keeping (Technical Services)

    STPRKLLI

    Simplified Transfer Pricing Record Keeping (Low Level Loans – Inbound)

    RUESA

    Reimbursement under Employee Secondment Agreements

    LVLRSA

    Low Value / Low Risk Service Agreements

    LVLRSPT

    Low Value / Low Risk Sale and Purchase Tangible Trading Stock Agreements

    IOS

    Issue of Ordinary Shares

      Last modified: 15 Jan 2018QC 51776