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  • Other kinds of IRPDs of a financial nature

    For reporting of IRPDs of a financial nature, the term 'financial nature' refers to dealings in financial instruments that would qualify as financial assets or financial liabilities under relevant Australian accounting standards or comparable foreign accounting standards.

    Table 51: Other kinds of IRPDs of a financial nature

    Code

    Description of transaction category

    GILDI

    Guarantee or indemnity of liability under a debt interest

    Any IRPDs in the nature of guarantee or indemnity of liability under a debt interest under Division 974 of the ITAA 1997.

    The expenditure and revenue for guarantees or indemnity include fees associated with a contract or arrangement under which a party agrees to perform an obligation or discharge a liability of another entity should that entity fail to do so.

    GIOKL

    Guarantee or indemnity of other kind of liability

    Any IRPDs in the nature of guarantee or indemnity of liability other than under a debt interest under Division 974 of the ITAA 1997.

    The expenditure and revenue for guarantees or indemnity include fees associated with a contract or arrangement under which a party agrees to perform an obligation or discharge a liability of another entity should that entity fail to do so.

    IN

    Insurance

    Any IRPDs in the nature of insurance.

    Insurance is a means by which an entity can protect itself with an insurance company against the risk of loss. Insurance is commonly categorised into general insurance, life insurance and health insurance.

    If the reporting entity engaged an intermediary (eg a broker) in arranging its insurance contracts, even if the intermediary was acting as an independent agent, the intermediary is considered to be acting on the reporting entity’s behalf. Therefore, the transactions undertaken by the intermediary on the reporting entity’s behalf should be included in this transaction category.

    The amounts reported for this transaction category should include the expenditure and revenue that would qualify as expenditure or revenue in relation to insurance contracts under relevant Australian accounting standards or comparable foreign accounting standards (eg premium revenue and claim recoveries).

    Expenditure incurred or revenue earned or derived for insurance services with international related parties, including activities associated with the management of insurance contracts (including activities predominantly undertaken through intermediaries), should be shown at transaction category ‘insurance services’.

    REIN

    Reinsurance

    Any IRPDs in the nature of reinsurance.

    Reinsurance is a means by which an insurance company can protect itself with other insurance companies against the risk of losses. Therefore, the question relating to reinsurance is applicable only to insurance companies.

    If the reporting entity engaged an intermediary (eg a broker) in arranging its reinsurance contracts, even if the intermediary was acting as an independent agent, the intermediary is considered to be acting on the reporting entity’s behalf. Therefore, the transactions undertaken by the intermediary on the reporting entity’s behalf should be included in this transaction category.

    The amounts reported for this transaction category should include the expenditure and revenue that would qualify as expenditure or revenue in relation to reinsurance contracts under relevant Australian accounting standards or comparable foreign accounting standards (eg premium revenue and commissions received from reinsurers).

    Expenditure incurred or revenue earned or derived for insurance services with international related parties, including activities associated with the management of insurance contracts (including activities predominantly undertaken through intermediaries), should be shown at transaction category ‘insurance services’.

    OFD

    Other financial dealings

    Any IRPDs of a financial nature excluding any of the following transaction categories:

    • Derivatives
    • Inward debt factoring
    • Outward debt factoring
    • Inward debt securitisation
    • Outward debt securitisation
    • Ordinary borrowings / loans
    • Trade financing
    • Bonds
    • Promissory notes
    • Convertible notes that are debt interests
    • Convertible shares that are debt interests
    • Redeemable preference shares that are debt interests
    • Other kinds of debt interests
    • Guarantee or indemnity of liability under a debt interest
    • Guarantee or indemnity of other kind of liability
    • Insurance
    • Reinsurance

     

    1. What is the transaction category?

    Select the transaction category for the IRPD transaction.

    (LCMSF32)

    1. Is this transaction part of a RAS?

    If this transaction is covered by an IRPD agreement in a RAS, indicate True.

    Otherwise indicate False.

    (LCMSF33)

    1. How many transactions are part of the RAS?

    If the transaction is part of a RAS, indicate the applicable range for the number of the transactions in the same RAS that were current during the income year:

    • Low (1–5)
    • Moderate (6–50)
    • High (51 or more)

    (LCMSF35)

    1. ABN or TFN of the Australian counterparty to the transaction/RAS

    Show the ABN or TFN of the Australian counterparty (which may be the reporting entity itself) to the transaction/RAS.

    (LCMSF83 and LCMSF84)

    1. Name of the IRP non-resident counterparty to the transaction/RAS

    Show the full name of the IRP non-resident counterparty to this transaction/RAS.

    The full name to be shown is the complete name of the IRP non-resident counterparty entity. While this would be expected to usually correspond with the name of the relevant party in any associated written agreement documentation, the full correct name of the entity should be shown at Part A even if this is not exactly the same as the name used in any associated written agreement documentation.

    (LCMSF37)

    1. Tax residency of the IRP non-resident counterparty to the transaction/RAS

    Show the country codeExternal Link for the country of tax residence of the IRP non-resident counterparty to this transaction/RAS.

    (LCMSF38)

    1. Amount of consideration paid (of a capital nature for income tax purposes) for the transaction/RAS

    The reporting rules for showing the amount of consideration paid of a capital nature at this question depend on the nature of the IRP's financial dealings.

    If an amount of a capital nature was paid by the reporting entity in connection with the guarantee or indemnity, insurance, reinsurance or other financial dealings transaction/RAS during the income year, show this amount based on the reporting entity’s accounting records.

    If no amount of a capital nature was paid by the reporting entity in connection with the guarantee or indemnity, insurance, reinsurance or other financial dealings transaction/RAS during the income year, show zero.

    (LCMSF39)

    1. Amount of consideration received (of a capital nature for income tax purposes) for the transaction/RAS

    The reporting rules for showing the amount of consideration received of a capital nature at this question depend on the nature of the IRP's financial dealings.

    If an amount of a capital nature was received by the reporting entity in connection with the guarantee or indemnity, insurance, reinsurance or other financial dealings transaction/RAS during the income year, show this amount based on the reporting entity’s accounting records.

    If no amount of a capital nature was received by the reporting entity in connection with the guarantee or indemnity, insurance, reinsurance or other financial dealings transaction/RAS during the income year, show zero.

    (LCMSF40)

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

    If non-monetary consideration of a capital nature was provided by the reporting entity in connection with this transaction/RAS during the income year, indicate True.

    Otherwise indicate False.

    (LCMSF85)

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

    If non-monetary consideration of a capital nature was obtained by the reporting entity in connection with this transaction/RAS during the income year, indicate True.

    Otherwise indicate False.

    (LCMSF86)

    1. Amount of expenditure (not of a capital nature for income tax purposes) for the transaction/RAS

    IRP financial dealing is IRP guarantee or indemnity of liability under a debt interest/guarantee or indemnity of other kind of liability

    Show the amount of expenditure not of a capital nature for income tax purposes including any guarantee or indemnity fees payable for the guarantee or indemnity IRP transaction/RAS during the income year based on the reporting entity’s accounting records.

    If there was no amount of expenditure not of a capital nature for income tax purposes for the guarantee or indemnity IRP transaction/RAS during the income year based on the reporting entity’s accounting records, show zero.

    IRP financial dealing is IRP insurance / reinsurance

    Show the amount of expenditure not of a capital nature for income tax purposes including any insurance premiums payable for the insurance or reinsurance IRP transaction/RAS during the income year based on the reporting entity’s accounting records.

    If there was no amount of expenditure not of a capital nature for income tax purposes for the insurance or reinsurance IRP transaction/RAS during the income year based on the reporting entity’s accounting records, show zero.

    IRP financial dealing is IRP other financial dealings

    Show the amount of expenditure not of a capital nature for income tax purposes for the other financial dealings IRP transaction/RAS during the income year based on the reporting entity’s accounting records.

    If there was no amount of expenditure not of a capital nature for income tax purposes for the other financial dealings IRP transaction/RAS during the income year based on the reporting entity’s accounting records, show zero.

    (LCMSF41)

    1. Amount of revenue (not of a capital nature for income tax purposes) for the transaction/RAS

    IRP financial dealing is IRP guarantee or indemnity of liability under a debt interest / guarantee or indemnity of other kind of liability

    Show the amount of revenue not of a capital nature for income tax purposes, including any guarantee or indemnity fees received for the guarantee or indemnity IRP transaction/RAS during the income year based on the reporting entity’s accounting records.

    If there was no amount of revenue not of a capital nature for income tax purposes for the guarantee or indemnity IRP transaction/RAS during the income year based on the reporting entity’s accounting records, show zero.

    IRP financial dealing is IRP insurance / reinsurance

    Show the amount of revenue not of a capital nature for income tax purposes, including any premiums received for the insurance or reinsurance IRP transaction/RAS during the income year based on the reporting entity’s accounting records.

    If there was no amount of revenue not of a capital nature for income tax purposes for the insurance or reinsurance IRP transaction/RAS during the income year based on the reporting entity's accounting records, show zero.

    IRP financial dealing is IRP other financial dealings

    Show the amount of revenue not of a capital nature for income tax purposes for the other financial dealings IRP transaction/RAS during the income year based on the reporting entity’s accounting records.

    If there was no amount of revenue not of a capital nature for income tax purposes for the other financial dealings IRP transaction/RAS during the income year based on the reporting entity’s accounting records, show zero.

    (LCMSF42)

    1. Was non-monetary consideration provided (not of a capital nature for income tax purposes) for the transaction/RAS?

    If non-monetary consideration not of a capital nature for income tax purposes was provided by the reporting entity in connection with this transaction/RAS during the income year, indicate True.

    Otherwise indicate False.

    (LCMSF44)

    1. Was non-monetary consideration obtained (not of a capital nature for income tax purposes) for the transaction/RAS?

    If non-monetary consideration not of a capital nature was obtained by the reporting entity in connection with this IRP transaction/RAS during the income year, indicate True.

    Otherwise indicate False.

    (LCMSF45)

    1. Amount of foreign exchange losses deducted for the transaction/RAS

    Show the amount of foreign exchange losses deducted for income tax purposes by the reporting entity in connection with this transaction/RAS under Division 775 of the ITAA 1997 or, if applicable, the taxation of financial arrangements (TOFA) provisions in Division 230 of the ITAA 1997 for the income year.

    For more information about the circumstances in which foreign exchange gains are assessable and foreign exchange losses are deductible for Australian income tax purposes, refer to Appendix 3.

    If there was no foreign exchange loss deducted for income tax purposes in connection with this transaction/RAS for the income year, show zero.

    (LCMSF87)

    1. Amount of foreign exchange gains returned for the transaction/RAS

    Show the amount of foreign exchange gains assessable for income tax purposes in connection with this transaction/RAS under Division 775 of the ITAA 1997 or, if applicable, the TOFA provisions in Division 230 of the ITAA 1997 for the income year.

    For more information about the circumstances in which foreign exchange gains are assessable and foreign exchange losses are deductible for Australian income tax purposes, refer to Appendix 3.

    If there was no foreign exchange gain assessable for income tax purposes in connection with this transaction/RAS, show zero for the income year.

    (LCMSF43)

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

    If the reporting entity does not know which transfer pricing methodology has been applied to this transaction/RAS, select the code UNKT (Unknown TP Method).

    If the reporting entity does not know which capital asset pricing methodology has been applied to this transaction/RAS, select the code UNKC (Unknown (CAP Method).

    (LCMSF46)

    1. What level of transfer pricing documentation has been prepared for this transaction/RAS?

    The level of transfer pricing documentation refers to the aggregate dollar amount of this transaction/RAS for which the reporting entity has prepared relevant transfer pricing documentation, expressed as a percentage of total dollar value of this transaction/RAS.

    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%

    If this transaction/RAS meets the conditions for the 7 = STPRK (Materiality) Simplified Transfer Pricing Record Keeping (STPRK) option in PCG 2017/2 Simplified Transfer Pricing Record Keeping Options, show the codes for the STPRK option applied to the transaction/RAS.

    (LCMSF47)

    1. If the reporting entity is a bank and this of transaction is in a RAS, has the special short term tenor rule for ordinary borrowings and ordinary loans been applied to this RAS?

    Always indicate False if the transaction category is not ordinary borrowings or ordinary loans.

    (LCMSF88)

    1. If the reporting entity is a bank and this of transaction is in a RAS, has the special short term tenor rule for short term derivatives been applied to this RAS?

    Always indicate False if the transaction category is not derivatives.

    (LCMSF128)

    1. If the reporting entity is a bank and this transaction is in a RAS, has the special short term tenor rule for FX derivatives been applied to this RAS?

    Always indicate False if the transaction category is not derivatives.

    (LCMSF129)

    1. If the reporting entity is an OBU, is this transaction/RAS an OB activity?

    If the reporting entity is an OBU and this transaction/RAS is an OB activity under sections 121D and 121EAA of the ITAA 1936, indicate True.

    Otherwise indicate False.

    (LCMSF63)

    1. Is this transaction/RAS covered by a category on the exclusions list?

    Indicate False, since none of the categories on the exclusions list can apply to these kinds of financial dealings.

    (LCMSF48)

    1. What category of the exclusions list applies to this transaction/RAS?

    Not applicable.

    (LCMSF49)

      Last modified: 26 Apr 2018QC 52807