IRPD debt interests (including ordinary loans and borrowings)

 

Table 32: IRPD debt interests (including ordinary loans and borrowings)

Code	Description of transaction category
OBL	Ordinary borrowings/loans (excluding trade financing) Any IRPDs in the nature of an ordinary borrowing or an ordinary loan, but excluding trade financing. ‘Borrowing’ and 'loan' should be given their ordinary meaning within the context of commercial and accounting practices. Ordinary borrowings/loans do not include raising finance by issue of, or assumption of, liabilities under: bonds promissory notes convertible notes shares other securities.
TFIN	Trade financing Any IRPDs in the nature of financing to fund trading liabilities including: issuing letters of credit (back-to-back, red-clause, revolving, stand-by, transferable) documentary credits documentary collections export credit.
BND	Bonds Any IRPDs in the nature of the issue, acquisition or holding of bonds including: corporate bonds sovereign bonds foreign currency bonds income bonds callable bonds zero coupon bonds.
PNOT	Promissory notes Any IRPDs in the nature of the issue, acquisition or holding of promissory notes. The term ‘promissory note’ has its ordinary meaning.
CNTDI	Convertible notes that are debt interests Any IRPDs in the nature of the issue, acquisition or holding of convertible notes that are debt interests under Division 974 of the ITAA 1997. The term ‘convertible note’ means promissory notes that may be converted into other debt or equity interests or securities upon specified contingent or non-contingent events.
CSTDI	Convertible shares that are debt interests Any IRPDs in the nature of the issue, acquisition or holding of convertible shares that are debt interests under Division 974 of the ITAA 1997. The term ‘convertible share’ means a share in a company of other equity interest that may be converted into other debt or equity interests or securities upon specified contingent or non-contingent events.
RPSDI	Redeemable preference shares that are debt interests Any IRPDs in the nature of the issue, acquisition or holding of redeemable preference shares that are debt interests under Division 974 of the ITAA 1997. The term ‘redeemable preference share’ means a share in a company that may be redeemed by the company or the holder upon specified contingent or non-contingent events under the terms or conditions of the share and which carries preferential rights as compared to other kinds of shares, such as a preferential right to a particular amount of distributions.
OKDI	Other kinds of debt interests Any IRPDs involving the issue, acquisition or holding of a debt interests under Division 974 of the ITAA 1997 but excluding the following transaction categories: 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

Special instructions for showing balances of borrowings, loans and other debt interests

For loans/borrowings, trade financing and other kinds of debt interests under Division 974 of the ITAA 1997, the average quarterly balance of the loan/borrowing or other debt interest during the income year is shown as indicated in the table below.

Table 33: Average quarterly balance

Average quarterly balance during income year	Where shown at Part A of local file
IRP loans by the reporting entity (ordinary loans or trade financing loans)	Question 7 – Amount of Consideration Paid (of a capital nature for income tax purposes)
IRP other debt interests held by the reporting entity (not ordinary loans or trade financing loans)	Question 7 – Amount of Consideration Paid (of a capital nature for income tax purposes)
IRP borrowings by the reporting entity (ordinary borrowings or trade financing borrowings)	Question 8 – Amount of Consideration Received (of a capital nature for income tax purposes)
IRP other debt interests issued or assumed by the reporting entity (not ordinary borrowings or trade financing borrowings)	Question 8 – Amount of Consideration Received (of a capital nature for income tax purposes)

The average quarterly balance of IRP borrowings, loans or other debt interests during the income year is calculated in the same way as quarterly balances of borrowings and loans shown at Item 11a of the IDS.

More detail about how to calculate and show the average quarterly balance of loans, borrowings and other debt interests at Questions 7 and 8 of Part A of the local file is provided below.

1. What is the transaction category?

Select the transaction category for the IRPD transaction.

(LCMSF32)

2. 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)

3. 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)

4. 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)

5. 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)

6. 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)

7. 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 debt interests.

IRPD debt interests are ordinary loans or trade financing loans

Show the amount of the average quarterly balance for the IRP ordinary loan transaction/RAS or for the IRP trade financing loan transaction/RAS during the income year determined by:

• adding up the amount of the balance of the loans based on the reporting entity’s accounting records at the start of the year and the amount of the balance of the loans based on the reporting entity’s accounting records at the end of each quarter
• dividing the result by five.

IRPD debt interests are bonds / promissory notes / convertible notes that are debt interests / convertible shares that are debt interests / redeemable preference shares that are debt interests / other debt interests held by reporting entity

Show the amount of the average quarterly balance of the cost of acquisition (cost or value) for the bonds, notes or other debt interests for the IRP transaction/RAS during the income year determined by:

• adding up the amount of the cost or value of the debt interests based on the reporting entity’s accounting records at the start of the year and the amount of the cost or value of the debt interests based on the reporting entity’s accounting records at the end of each quarter
• dividing the result by five.

(LCMSF39)

8. 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 debt interests.

If the IRPD debt interests are ordinary borrowings or trade financing borrowings, show the amount of the average quarterly balance of the IRP ordinary borrowing transaction/RAS or for the IRP trade financing borrowing transaction/RAS during the income year determined by:

• adding up the amount of the balance of the borrowing based on the reporting entity’s accounting records at the start of the year and the amount of the balance of the borrowing based on the reporting entity’s accounting records at the end of each quarter
• dividing the result by five.

If the IRPD debt interests are bonds / promissory notes / convertible notes that are debt interests / convertible shares that are debt interests / redeemable preference shares that are debt interests / other debt interests issued or assumed by reporting entity, show the amount of the average quarterly balance of the proceeds received for issue or assumption (price or value) of the bonds, notes or other debt interests for the IRP transaction/RAS during the income year determined by:

• adding up the amount of the price or value of the debt interest based on the reporting entity’s accounting records at the start of the year and the amount of the price or value of the debt interest based on the reporting entity’s accounting records at the end of each quarter
• dividing the result by five.

(LCMSF40)

9. 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)

10. 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)

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

The reporting rules for showing the amount of expenditure not of a capital nature for income tax purposes at this question depend on the nature of the IRP debt interests.

IRPD debt interests are ordinary borrowing or trade financing borrowing

Show the amount of interest paid and any other expenditure not of a capital nature for income tax purposes for the IRP ordinary borrowing or trade financing borrowing transaction/RAS during the income year based on the reporting entity’s accounting records, excluding interest that has been capitalised based on the reporting entity’s accounting records.

If there was no amount of interest paid or any other expenditure not of a capital nature for the IRP borrowing during the income year for the IRP ordinary borrowing or trade financing borrowing transaction/RAS during the income year, show zero.

IRPD debt interests are bonds / promissory notes / convertible notes that are debt interests / convertible shares that are debt interests / redeemable preference shares that are debt interests / other debt interests issued or assumed by reporting entity

Show the amount of interest paid, any other return paid or payable and any other expenditure not of a capital nature for income tax purposes for the IRP debt interest transaction/RAS for the income year based on the reporting entity’s accounting records, excluding interest that has been capitalised based on the reporting entity’s accounting records.

If there was no amount of interest paid, any other return paid or payable or any other expenditure not of a capital nature for the IRP debt interest transaction/RAS during the income year, show zero.

(LCMSF41)

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

The reporting rules for showing the amount of revenue not of a capital nature for income tax purposes at this question depend on the nature of the IRP debt interests.

IRPD debt interests are ordinary loans or trade financing loans

Show the amount of interest received and any other revenue not of a capital nature for income tax purposes for the IRP ordinary loan or trade financing loan transaction/RAS during the income year based on the reporting entity’s accounting records, excluding interest that has been capitalised based on the reporting entity’s accounting records.

If there was no amount of interest received or any other revenue not of a capital nature for the IRP borrowing during the income year for the IRP ordinary loan or trade financing loan transaction/RAS during the income year, show zero.

IRPD debt interests are bonds / promissory notes / convertible notes that are debt interests / convertible shares that are debt interests / redeemable preference shares that are debt interests / Other debt interests held by reporting entity

Show the amount of interest received, any other return received or receivable and any other revenue not of a capital nature for income tax purposes for the IRP debt interest transaction/RAS for the income year based on the reporting entity’s accounting records, excluding interest that has been capitalised based on the reporting entity’s accounting records.

If there was no amount of interest received, any other return received or receivable or any other revenue not of a capital nature for the IRP debt interest transaction/RAS during the income year, show zero.

(LCMSF42)

13. 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)

14. 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)

15. 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)

16. 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.

(LCMSF43)

17. 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)

18. 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 either of the following Simplified Transfer Pricing Record Keeping (STPRK) options, outlined in PCG 2017/2 Simplified Transfer Pricing Record Keeping Options, show the code(s) for the STPRK option applied to the transaction/RAS:

7 = STPRK (Materiality)

8 = STPRK (Low Level Loans – Inbound)

(LCMSF47)

19. 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?

If the reporting entity has an unconditional or conditional Australian banking licence and has applied the special short term tenor rule for ordinary borrowings and ordinary loans, indicate True.

Otherwise indicate False.

(LCMSF88)

20. 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)

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?

Always indicate False if the transaction category is not derivatives.

(LCMSF129)

22. 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)

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

If this transaction/RAS is covered by the Simplified Transfer Pricing Record Keeping (Low Level Loans – Inbound) category on the exclusions list, indicate True.

Otherwise indicate False.

(LCMSF48)

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

If the Simplified Transfer Pricing Record Keeping (Low Level Loans – Inbound) category on the Exclusions List applies to this transaction/RAS and you have indicated True to Question 23, select the code STPRKLLI.

(LCMSF49)

Reporting examples: IRPDs of a financial nature