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  • IRPDs involving disposal or acquisition of tangible property of a non-revenue (capital) nature

    Table 52: IRPDs involving disposal or acquisition of tangible property of a non-revenue (capital) nature

    Code

    Description of transaction category

    RPRT

    Real property

    Any IRPDs in the nature of disposal or acquisition of real property of a non-revenue (capital) nature.

    PLEQ

    Plant or equipment

    Any IRPDs in the nature of disposal or acquisition of plant or equipment of a non-revenue (capital) nature.

    OTPRTY

    Other tangible property

    Any IRPDs in the nature of disposal or acquisition of tangible property of a non-revenue (capital) nature excluding the following property:

    • real property
    • plant or equipment.

     

    1. Transaction Identifier

    Show the Transaction ID for the transaction being reported.

    (LCMSF31)

    1. Related Transaction Identifier(s)

    Show all Transaction IDs that are directly connected to the transaction being reported.

    (LCMSF206)

    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. Australian counterparty name

    Show the full name of the Australian counterparty (which may be the reporting entity itself) to this transaction/RAS.

    LCMSF207)

    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. Was the transaction/RAS entered into by the non-resident counterparty in the course of its business operations carried on through a permanent establishment in a different country to its country of tax residence?

    Indicate True if the transaction/RAS was entered into by the non-resident counterparty in the course of its business operations carried on through a PE in a different country to its country of tax residence.

    Otherwise indicate False.

    (LCMSF208)

    1. Country of permanent establishment of non-resident counterparty

    This question applies only if you answer True to Question 10.

    Show the country codeExternal Link of the PE.

    (LCMSF209)

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

    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 its 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 its 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 that is 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 that is not of a capital nature in connection with this transaction/RAS during the income year, show zero.

    (LCMSF42)

    1. Average balance of debt interests

    Not applicable.

    (LCMSF210)

    1. Capitalised interest deducted

    Not applicable.

    (LCMSF211)

    1. Average balance of debt interests

    Not applicable.

    (LCMSF212)

    1. Capitalised interest returned

    Not applicable.

    (LCMSF213)

    1. Book values

    Not applicable.

    (LCMSF214)

    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. Did you enter into a deferred foreign currency payment arrangement in relation to this transaction

    Not applicable for this transaction category.

    (LCMSF215)

    1. Foreign Currency Reporting Type

    Not applicable for this transaction category.

    (LCMSF216)

    1. Foreign Currency Code

    Not applicable for this transaction category.

    (LCMSF217)

    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 6.

    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. Foreign Currency Code

    Show the Foreign Currency Code in relation to foreign exchange losses deducted for the transaction/RAS

    (LCMSF219)

    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 6.

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

    (LCMSF43)

    1. Foreign Currency Code

    Show the Foreign Currency CodeExternal Link in relation to foreign exchange gains returned for the transaction/RAS

    (LCMSF221)

    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%

    This transaction/RAS will not meet the conditions for any of the simplified record keeping (STPRK) options in PCG 2017/2 Simplified Transfer Pricing Record Keeping Options since it is not a services or loan arrangement and it involves an IRPD of a capital nature.

    (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 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?

    Always indicate False since acquisition or disposal of tangible property of a non-revenue (capital) nature is not an OB activity under section 121D of the ITAA 1936.

    (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 a disposal or acquisition or disposal of tangible property of a non-revenue (capital) nature.

    (LCMSF48)

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

    Not applicable.

    (LCMSF49)

    1. Transaction Comments

    Provide any relevant comments in respect of the transaction/RAS.

      Last modified: 14 Jun 2019QC 56216