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  • Other revenue IRPDs

    Table 14: Other revenue IRPDs

    Code

    Description of transaction category

    CCA

    Cost contribution arrangement

    Any IRPDs in the nature of a cost contribution arrangement for developing, producing or obtaining assets or rights and defining the interests of each participant in those assets or rights.

    This excludes IRPD arrangements solely involving provision or obtaining of services, and where the parties do not all obtain an interest in property or other rights or benefits under the arrangement. Such arrangements are treated as comprising the relevant IRPD services transactions for local file reporting purposes.

    ORIRPD

    Other revenue (non-financial dealing) IRPDs

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

    • Tangible property of a revenue nature
    • Rights to use IP
    • Other rights to use, supply or receive where consideration is royalty under section 6(1)
    • Licence fees
    • Rent of real property
    • Hire or lease of plant or equipment
    • Lease or hire of other property or rights
    • Share based employment remuneration
    • Cost contribution arrangement
    • IRPD service arrangements
    • IRPD Debt Interests (including ordinary loans and borrowings)
    • IRPD Derivative transactions
    • Other kinds of IRPDs of a financial nature
    • IRPDs involving disposal or acquisition of tangible property of a non-revenue (capital) nature
    • IRPDs involving disposal or acquisition of intangible property or rights of a non-revenue (capital) nature.

     

    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

    If an amount of a capital nature was paid by the reporting entity in connection with this 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 this 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

    If an amount of a capital nature was received by the reporting entity in connection with this 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 this 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

    Show the amount of expenditure not of a capital nature for income tax purposes in connection with this 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 in connection with this transaction/RAS during the income year, show zero.

    (LCMSF41)

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

    Show the amount of revenue not of a capital nature for income tax purposes in connection with this 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 in connection with this transaction/RAS during the income year, 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 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 one of the following Simplified Transfer Pricing Record Keeping (STPRK) options, outlined in PCG 2017/2 Simplified Transfer Pricing Record Keeping Options, show the codes for the STPRK option applied to the transaction/RAS:

    7 = STPRK (Materiality)

    8 = STPRK (Small Business)

    9 = STPRK (Distributors)

    (LCMSF47)

    1. If the reporting entity is a bank and this 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 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 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?

    If this transaction/RAS is covered by one of the following categories on the exclusions list, indicate True.

    • RUESA – Reimbursement under employee secondment agreements
    • LVLRSPT – Low value / low risk sale and purchase tangible trading stock agreements

    Otherwise indicate False.

    (LCMSF48)

    1. What category of the Exclusions List applies to this transaction/RAS?

    If you indicated True to Question 23, select the category on the exclusions list which applies to this transaction/RAS.

    (LCMSF49)

    Reporting example: Other revenue IRPDs

    Example 9: Cost contribution arrangement with Bermudan and US IRPs

    Aus Co is a company that is resident in Australia for tax purposes.

    Aus Co has an income tax year ending 30 June.

    Aus Co’s functional currency for Australian tax purposes is Australian dollars.

    Prior to the income year, Aus Co entered into a cost contribution agreement with an IRP resident for tax purposes in Bermuda (Bermuda Co) and an IRP resident for tax purposes in the US (US Co). Under the terms of the cost contribution agreement:

    • Bermuda Co and US Co agreed to pay a specified portion of the costs incurred by Aus Co in relation to developing new plant and equipment in connection with its Australian mining operations
    • US Co agreed to make certain premises available to Aus Co for the development activities
    • Bermuda Co agreed to contribute use of certain patents and registered designs for the development activities
    • Bermuda Co and US Co would have title to a specified extent to any patents or designs created by the development activities conducted by Aus Co.

    During the income year Aus Co has patented inventions resulting from Aus Co’s development activities under the cost contribution arrangement. The patents for these inventions were issued in the name of Bermuda Co.

    The amount of costs incurred by Aus Co in performing the development activities covered by the cost contribution arrangement that were reimbursed by Bermuda Co and US Co under the arrangement is shown in the table below.

    Table 15: Costs incurred by Aus Co
    Table 15: Costs incurred by Aus Co

    Nature of costs incurred by Aus Co

    Amount of costs incurred by Aus Co

    Amount reimbursed by Bermuda Co

    Amount reimbursed by US Co

    Purchase of plant and equipment

    $10m

    $1m

    $2m

    Salary and wages

    $5m

    $1m

    $1m

    All costs that were incurred or reimbursed by Aus Co under the cost contribution arrangement were incurred or reimbursed in Australian dollars.

    Aus Co has not yet earned any revenue as a result of the development activities under the cost contribution arrangement, except for payments made by Bermuda Co and US Co as reimbursement of the salary and wage costs incurred by Aus Co under the cost contribution arrangement.

    The only monetary consideration of a capital nature obtained by Aus Co was the reimbursement by Bermuda Co and US Co of costs for the plant and equipment.

    Aus Co did provide non-monetary consideration of a capital nature to Bermuda Co, being title to the patents for the inventions resulting from Aus Co’s development activities under the cost contribution arrangement.

    Aus Co did obtain non-monetary consideration not of a capital nature for income tax purposes from Bermuda Co in relation to the cost contribution arrangement, being the right to use certain patents and registered designs made available by Bermuda Co.

    Aus Co did obtain non-monetary consideration not of a capital nature for income tax purposes from US Co in relation to the cost contribution arrangement, being the right to use or access certain premises made available by US Co.

    Aus Co has applied the transfer pricing methodology ‘Cost contribution arrangement’ to all payments and benefits obtained or made by Aus Co under the cost contribution arrangement.

    Aus Co has prepared relevant contemporaneous transfer pricing documentation for 100% of the cost contribution arrangement.

    Aus Co completes the questions for the IRP transactions/RAS in this example based on its accounting records as shown in the following tables. At this stage, the form can only support one non-resident IRP counterparty.


    Table 16: Completed entry – Cost contribution arrangement with Bermuda Co
    Table 16: Completed entry – Cost contribution arrangement with Bermuda Co

    Question no.

    Question label

    Response

     na

    Local file – Part A Transaction Identifier

    [Transaction ID]

    1

    Transaction category

    CCA

    2

    Is this transaction part of a RAS?

    False

    3

    How many transactions are part of the RAS?

    na

    4

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

    [ABN or TFN]

    5

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

    Bermuda Co

    6

    Tax residence of the IRP non-resident counterparty to the transaction/RAS

    BM

    7

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

    0

    8

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

    1000000

    9

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

    True

    10

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

    False

    11

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

    0

    12

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

    1000000

    13

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

    False

    14

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

    True

    15

    Amount of foreign exchange losses deducted for the transaction/RAS

    0

    16

    Amount of foreign exchange gains returned for the transaction/RAS

    0

    17

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

    CCA

    18

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

    6

    19

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

    False

    20

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

    False

    21

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

    False

    22

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

    False

    23

    Is this transaction/RAS covered by a category on the Exclusions List?

    False

    24

    What category of the Exclusions List applies to this transaction/RAS?

    na


     Table 17: Completed entry – Cost contribution arrangement with US Co
     Table 17: Completed entry – Cost contribution arrangement with US Co

    Question no.

    Question label

    Response

    na

    Local file – Part A Transaction Identifier

    [Transaction ID]

    1

    Transaction category

    CCA

    2

    Is this transaction part of a RAS?

    False

    3

    How many transactions are part of the RAS?

    na

    4

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

    [ABN or TFN]

    5

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

    US Co

    6

    Tax residence of the IRP non-resident counterparty to the transaction/RAS

    US

    7

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

    0

    8

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

    2000000

    9

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

    False

    10

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

    False

    11

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

    0

    12

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

    1000000

    13

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

    False

    14

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

    True

    15

    Amount of foreign exchange losses deducted for the transaction/RAS

    0

    16

    Amount of foreign exchange gains returned for the transaction/RAS

    0

    17

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

    CCA

    18

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

    6

    19

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

    False

    20

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

    False

    21

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

    False

    22

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

    False

    23

    Is this transaction/RAS covered by a category on the Exclusions List?

    False

    24

    What category of the Exclusions List applies to this transaction/RAS?

    na

     

    End of example
      Last modified: 26 Apr 2018QC 52807