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  • Appendices

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    Appendix 1: Exclusion list and codes

    Table 58: Exclusion list and codes

    Code

    Exclusion list

    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)

    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

    Appendix 2: Accounting records / income tax records

    Table 59: Accounting records / income tax records

    Code

    Transaction category

    Accounting records / income tax records

    TPRN

    Tangible property of a revenue nature

    Accounting records

    RUIP

    Rights to use IP

    Income tax records

    ORSR

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

    Income tax records

    LF

    Licence fees

    Income tax records

    RRP

    Rent of real property

    Accounting records

    HLPE

    Hire or lease of plant or equipment

    Accounting records

    LHORP

    Lease or hire of other property or rights

    Accounting records

    TRS

    Treasury related services

    Accounting records

    MAS

    Management and administration services

    Accounting records

    INSERV

    Insurance services

    Accounting records

    REINSERV

    Reinsurance services

    Accounting records

    RD

    Research and development services

    Accounting records

    SAM

    Sales and marketing services

    Accounting records

    SITS

    Software and IT services

    Accounting records

    TS

    Technical services

    Accounting records

    LS

    Logistics services

    Accounting records

    AM

    Asset management services

    Accounting records

    OS

    Other services

    Accounting records

    CCIRS

    Cross currency interest rate swap

    Accounting records

    CDCSFFO

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

    Accounting records

    FFIRS

    Fixed for floating interest rate swap (not cross currency)

    Accounting records

    OIRD

    Other interest rate derivative (not cross currency)

    Accounting records

    CDS

    Credit default swap

    Accounting records

    AS

    Asset swap

    Accounting records

    CDCS

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

    Accounting records

    OD

    Other derivative

    Accounting records

    IDF

    Inward debt factoring

    Accounting records

    ODF

    Outward debt factoring

    Accounting records

    IDSEC

    Inward debt securitisation

    Accounting records

    ODSEC

    Outward debt securitisation

    Accounting records

    OBL

    Ordinary borrowings/loans (excluding trade financing)

    Accounting records

    TFIN

    Trade financing

    Accounting records

    BND

    Bonds

    Accounting records

    PNOT

    Promissory notes

    Accounting records

    CNTDI

    Convertible notes that are debt interests

    Accounting records

    CSTDI

    Convertible shares that are debt interests

    Accounting records

    RPSDI

    Redeemable preference shares that are debt interests

    Accounting records

    OKDI

    Other kinds of debt interests

    Accounting records

    GILDI

    Guarantee or indemnity of liability under a debt interest

    Accounting records

    GIOKL

    Guarantee or indemnity of other kind of liability

    Accounting records

    IN

    Insurance

    Accounting records

    REIN

    Reinsurance

    Accounting records

    OFD

    Other financial dealings

    Accounting records

    ORIRPD

    Other revenue IRPDs

    Accounting records

    RPRT

    Real property

    Accounting records

    PLEQ

    Plant or equipment

    Accounting records

    OTPRTY

    Other tangible property

    Accounting records

    ASIP

    Assignment of IP

    Accounting records

    IOSH

    Issue of ordinary shares

    Accounting records

    AOSH

    Assignment of ordinary shares

    Accounting records

    IEIOOS

    Issue of equity interest other than ordinary shares

    Accounting records

    AQIOS

    Assignment of equity interest other than ordinary shares

    Accounting records

    ASSD

    Assignment of debts

    Accounting records

    ASSL

    Assignment of liabilities

    Accounting records

    ASSBC

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

    Accounting records

    ASSOPR

    Assignment of other intangible property or rights

    Accounting records

    SBER

    Share based employment remuneration

    Income tax records

    CCA

    Cost contribution arrangement

    Accounting records

    Appendix 3: Assessable foreign exchange gains and deductible foreign exchange losses for Australian income tax

    If the reporting entity has returned foreign exchange gains or deducted foreign exchange losses for its relevant IRP transaction/RAS for Australian income tax purposes, you need to show the amounts returned and deducted at Questions 15 and 16 in Part A of the local file for the relevant IRP transaction/RAS.

    This may include foreign exchange gains the reporting entity has returned and foreign exchange losses it has deducted during the income year for trade-related financial liabilities or receivables which may potentially arise if the reporting entity did not pay the IRP, or was not paid by the IRP, when the price for goods or fees for services are payable.

    Examples include:

    • foreign currency intercompany liabilities for amounts payable by the reporting entity for purchase of commodities from international related parties which are satisfied during the income year
    • foreign currency intercompany receivables for amounts payable to the reporting entity for provision of services to international related parties which are satisfied during the income year.

    Assessable foreign exchange gains and deductible foreign exchange losses for income tax purposes are determined under Division 775 of the ITAA 1997 or, if applicable, under the taxation of financial arrangements (TOFA) provisions in Division 230 of the ITAA 1997.

    For more guidance on entities covered by TOFA and the operation of TOFA, refer to Guide to the taxation of financial arrangements (TOFA).

    In other scenarios assessable foreign exchange gains and deductible foreign exchange losses are determined under the provisions in Subdivisions 775-B to 775-E and Subdivisions 960-C and 960-D of the ITAA 1997.

    Foreign exchange gain refers to a foreign exchange gain attributable to fluctuations in a currency exchange rate you make as a result of a forex realisation event under the provisions.

    Foreign exchange loss refers to a foreign exchange loss attributable to fluctuations in a currency exchange rate you make as a result of a forex realisation event under the provisions.

    Under Subdivision 775-B of the ITAA 1997 there are five main types of forex realisation events:

    1. Forex realisation event 1 happens if you dispose of foreign currency, or a right to receive foreign currency, to another entity.
    2. Forex realisation event 2 happens if you cease to have a right to receive foreign currency (other than because you disposed of the right to another entity).
    3. Forex realisation event 3 happens if you cease to have an obligation to receive foreign currency.
    4. Forex realisation event 4 happens if you cease to have an obligation to pay foreign currency.
    5. Forex realisation event 5 happens if you cease to have a right to pay foreign currency.

    There are also special rules:

    • under Subdivision 775-C of the ITAA 1997, for rollover for facility agreements and special rules for securities issued under the facility agreements
    • under Subdivision 775-D of the ITAA 1997, providing an election to disregard forex realisation events 2 and 4 for qualifying forex accounts not exceeding $250,000
    • under Subdivision 775-E of the ITAA 1997, providing a choice to use the retranslation method for qualifying forex accounts instead of forex realisation events 2 and 4.

    For more information about foreign exchange gains and losses, see Foreign exchange gains and losses.

    Appendix 4: Glossary

    Table 60: Glossary

    Term

    Meaning

    Assignment

    Assignment in law or in equity, including without limitation assignment by declaration of trust

    Australian entity

    An entity which is an Australian resident for tax purposes

    Debts

    Debt receivables including loan receivables

    Debt interest

    A debt interest under Division 974 of the ITAA 1997

    Equity interest

    An equity interest under Division 974 and section 820-930 of the ITAA 1997

    Foreign entity

    Any entity which is not an Australian resident for tax purposes

    Highest quality financial accounts

    The reporting entity's financial reports that report on the reporting entity's assets, liabilities, equity, income, expenses and cashflows (excluding assets, liabilities, equity, income, expenses and cashflows of other entities which are not members of the reporting entity's consolidated or MEC group for Australian tax purposes) for the income year, including where relevant more than one set of reports, which satisfy the following requirements:

    1. If there are general purpose financial reports prepared in accordance with AASB, IFRS or US GAAP, those reports.
    2. In the case of a reporting entity which is a member of a foreign owned global group, if there are no reports satisfying the requirements in 1, but there are group reporting packs submitted to the reporting entity's overseas global group entities for the purpose of preparing consolidated financial statements and/or central reporting, those reports.
    3. If there are no reports satisfying the requirements in 1or 2, but there are other reports including but not limited to separate financial statements or special purpose financial statements prepared in accordance with AASB, IFRS or USGAAP, those reports.
    4. If there are no reports satisfying the requirements in 1, 2, or 3, but there are management accounts, those reports.
    5. If there are no reports satisfying the requirements in 1, 2, 3 or 4, but there are other reports, those reports.
     

    International related party

    See What is an IRP and IRPD?

    Intellectual property (IP)

    Trademark, patent, design, copyright, other intellectual property or similar property or rights

    International dealings schedule (IDS)

    The International dealings schedule, being the income tax return schedule required to be completed as part of the company tax return, partnership tax return, trust tax return or attribution managed investment trust (AMIT) tax return if certain criteria are met

    International related party dealings (IRPD)

    As defined in the IDS instructions

    OBU

    An offshore banking unit under subsection 128AE(2) of the ITAA 1936 or section 717-710 of the ITAA 1997

    Ordinary shares

    Shares issued by a company carrying proportionate rights to voting and to profit and capital distributions, and carrying no special rights

    Short form exceptions list

    List of kinds of transactions, that if entered into by the reporting entity will mean it will not be eligible to complete the short form local file

    Relevant agreement series

    As described in Local file – Part B: Guidance on providing international related party agreements

     

      Last modified: 26 Apr 2018QC 52807