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  • Local file instructions: Part A and Part B

    While these instructions are not a guide to income tax law, you can use them to help you complete Part A and Part B of the local file.

    The local file collects information and relevant documentation for international related party dealings (IRPDs). The specific information requirements of the local file are contained in the local file – high level design and associated specifications of the simplified message structure table (MST). Reference is made to the specific elements of the MST via element IDs in the form of 'LCMSFXXX'.

    The local file must be electronically lodged in the approved form via one of the following mechanisms:

    The meaning of international related party (IRP) and IRPDs are the same as in the International dealings schedule (IDS).

    A key design feature of the local file is the requirement to show values in Part A and provide agreements in Part B for individual IRP transactions, unless the transaction is covered by:

    These are the consequences of an IRP transaction being covered by an agreement which is in a RAS:

    • The values required to be shown in Part A of the local file for each kind of transaction category covered by the RAS are aggregated for all the transactions covered by agreements in the same RAS.
    • The criteria in the exclusions list are applied on the basis of these aggregated values.
    • In Part B of the local file, agreement documentation only needs to be provided for a material representative agreement in the RAS that was current during the income year.

    Where a reporting entity enters into a transaction with multiple IRP non-resident counterparties, they must complete Part A of the local file for each IRP non-resident counterparty to the transaction.

    Additionally, the local file has been designed so that, unless a transaction is on the exclusions list, the values shown in Part A of the local file for a particular transaction are linked with an agreement provided in Part B or an agreement previously provided to the ATO, if an agreement exists.

    If a single agreement covers more than one kind of transaction category, each of the transactions shown in Part A will need to be linked to the same agreement in Part B of the local file.

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      Last modified: 10 Aug 2017QC 52807