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  •  IRPDs in tangible property of a revenue nature

    Table 1: Tangible property of a revenue nature

    Code

    Description of transaction category

    TPRN

    Tangible property of a revenue nature.

    Any IRPDs in tangible property of a revenue nature, including sale or purchase of trading stock and raw materials.

    The definition of trading stock in section 70-10 of the Income Tax Assessment Act 1997 (ITAA 1997) should be used to determine what trading stock is for the purpose of this question.

    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/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 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

    Indicate True if you have entered into a deferred foreign currency payment arrangement in relation to this transaction.

    Otherwise indicate False.

    (LCMSF215)

    1. Foreign Currency Reporting type

    This question applies only if you answer True to Question 25.

    Please indicate the type of foreign currency deferred payment arrangement entered into:

    1 = Regular / short term foreign currency deferred payment arrangements

    2 = Irregular or longer term foreign currency deferred payment arrangements

    If you have indicated 1, then you will need to only provide the Foreign Currency CodeExternal Link at Question 27.

    If you have indicated 2, then you will need to show your foreign exchange gains / losses at the relevant IRPD foreign currency deferred payment arrangements transaction category.

    (LCMSF216)

    1. Foreign Currency Code

    This question applies only if you answer True to Question 25 and indicate that you entered into a Regular / short term foreign currency deferred payment arrangement at Question 26.

    Show the Foreign Currency CodeExternal Link applicable to the foreign currency deferred payment arrangement.

    (LCMSF217)

    1. Amount of foreign exchange losses deducted for the transaction/RAS

    This question applies only if you answer False to Question 25.

    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

    This question applies only if you answer False to Question 25.

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

    (LCMSF219)

    1. Amount of foreign exchange gains returned for the transaction/RAS

    This question applies only if you answer False to Question 25.

    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

    This question applies only if you answer False to Question 25.

    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%

    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 38, select the category on the exclusions list which applies to this transaction/RAS.

    (LCMSF49)

    1. Transaction Comments

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

    (LCMSF222)

    Reporting examples: IRPDs in tangible property of a revenue nature

    Example 1: Sale of iron ore to Singapore IRP

    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.

    During the income year Aus Co sold iron ore to its subsidiary in Singapore (Singapore Co) in more than 25 transactions under agreements on the same terms except for date, price, volume and delivery. The 25 transactions for the sale of iron ore are therefore in the same RAS in accordance with Appendix 8.

    The aggregate sale price payable to Aus Co by Singapore Co for these sales was A$350 million as recorded in Aus Co’s accounting records.

    Aus Co incurred expenditure of A$17 million for fees and commissions paid to Singapore Co for services provided to Aus Co in connection with sales and marketing of the iron ore.

    Aus Co did not return foreign exchange gains or deduct foreign exchange losses during the income year for the sale of the iron ore because Aus Co had an Australian dollar functional currency for Australian tax purposes and the sale of the iron ore was for an Australian dollar sale price.

    Aus Co did not enter into any deferred foreign currency payment arrangements.

    Aus Co did not pay or obtain any consideration of a capital nature in relation to the sale of iron ore to Singapore Co.

    Aus Co did not provide or obtain any non-monetary consideration in relation to the sale of iron ore to Singapore Co.

    Aus Co shows the transaction category for the sale of iron ore to Singapore Co by using the transaction category ‘tangible property of a revenue nature’ which covers international related party dealings involving tangible property of a revenue nature, including sale or purchase of trading stock or raw materials.

    Aus Co has applied the transfer pricing methodology ‘Comparable uncontrolled price method’ to this transaction/RAS.

    Aus Co has prepared relevant contemporaneous transfer pricing documentation for 100% of this transaction/RAS.

    The total amount returned in the income year by Aus Co in connection with the transaction/RAS is not less than A$2 million or less than 2% of Aus Co’s total IRPD revenue, so the transaction/RAS does not satisfy the category of ‘low value / low risk sale and purchase tangible trading stock agreements’ on the exclusions list.

    Aus Co is not an OBU.

    Singapore Co is a company that is resident in Singapore for tax purposes.

    Singapore Co does not carry on its business operations through a permanent establishment.

    Aus Co completes the Questions for the transaction/RAS in this example based on its accounting records as shown in the following table.

    Table 2: Completed entry – Sale of iron ore to IRP (Tangible property of a revenue nature)

    Question no.

    Question label

    Response

    1

    Transaction Identifier

    [Transaction ID]

    2

    Related Transaction Identifier(s)

    [Transaction IDs]

    3

    Transaction category

    TPRN

    4

    Is this transaction part of a RAS?

    True

    5

    How many transactions are part of the RAS?

    Moderate

    6

    Australian counterparty name

    [Australian counterparty name]

    7

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

    [ABN or TFN]

    8

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

    Singapore Co

    9

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

    SG

    10

    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?

    False

    11

    Country of permanent establishment counterparty

    na

    12

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

    0

    13

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

    0

    14

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

    False

    15

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

    False

    16

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

    0

    17

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

    350000000

    18

    Average balance of debt interests

    na

    19

    Capitalised interest deducted

    na

    20

    Average balance of debt interests

    na

    21

    Capitalised interest returned

    na

    22

    Book values

    na

    23

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

    False

    24

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

    False

    25

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

    False

    26

    Foreign Currency Reporting Type

    na

    27

    Foreign Currency Code

    na

    28

    Amount of foreign exchange losses deducted for the transaction/RAS

    0

    29

    Foreign Currency Code

    na

    30

    Amount of foreign exchange gains returned for the transaction/RAS

    0

    31

    Foreign Currency Code

    na

    32

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

    CUP

    33

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

    6

    34

    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

    35

    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

    36

    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

    37

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

    False

    38

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

    False

    39

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

    na

    40

    Transaction Comments

    [Comments]

    The expenditure Aus Co incurred for fees and commissions paid to Singapore Co for services provided to Aus Co in connection with sale of the iron ore is expenditure for services provided by an IRP which will be shown for the relevant services transaction. This is covered in Example 4.

    End of example

     

    Example 2: Purchases of homewares from Irish IRP

    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.

    During the income year Aus Co purchases a range of homeware and kitchen goods from an Irish subsidiary (Ireland Co) of its ultimate UK parent company, involving eight separate shipments of goods, under the terms of an umbrella procurement agreement and associated specific agreement documentation with Ireland Co.

    The eight shipments were of the same kinds of goods and the purchase of the goods were on the same terms except for date, volume, price and delivery. The purchase of the goods in the eight shipments from the same IRP were therefore in the same RAS in accordance with Appendix 8.

    The aggregate purchase price payable by Aus Co to Ireland Co for these sales was US$12 million as recorded in Aus Co’s accounting records. The Australian dollar equivalent of the total of the US dollar purchase price on the date of billing was $15 million as recorded in Aus Co’s accounting records.

    Under the terms of the procurement and sale agreements with Ireland Co, the purchase price payable by Aus Co was due for payment by Aus Co 60 days after billing. For all shipments Aus Co satisfied payment of the purchase price in accordance with the terms of the procurement and sale agreements.

    Aus Co returned assessable foreign exchange gains of $200,000 and deducted foreign exchange losses of $150,000 under Subdivision 775-B of the ITAA 1997 during the income year for foreign exchange gains and foreign exchange losses made as a result of fluctuations in the AUD/USD exchange rate between the date of billing and the date of payment by Aus Co for the purchase of the homeware goods.

    Aus Co did not have any revenue or any other expenditure as recorded in Aus Co’s accounting records for the purchase of the homeware goods from Ireland Co.

    Aus Co did not provide or obtain any consideration of a capital nature in relation to the purchase of the homeware goods from Ireland Co.

    Aus Co did not provide or obtain any non-monetary consideration in relation to the purchase of the homeware goods from Ireland Co.

    Aus Co shows the transaction category for the purchase of the homeware goods from Ireland Co by using the transaction category ‘tangible property of a revenue nature', which covers international related party dealings involving tangible property of a revenue nature, including sale or purchase of trading stock or raw materials.

    Aus Co has applied the transfer pricing methodology ‘Comparable uncontrolled price method’ to this transaction/RAS.

    Aus Co has prepared relevant contemporaneous transfer pricing documentation for 100% of this transaction/RAS.

    The total amount returned in the income year by Aus Co in connection with this tangible goods transaction/RAS is less than A$2 million or less than 2% of Aus Co’s total IRPD expenditure.

    The homeware and kitchen goods were not purchased from Ireland Co in connection with:

    • the use or enjoyment of any trademark, patent, design, copyright, other intellectual property, secret formula or process or similar property or rights, or
    • any other IRP agreement.

    The agreements in the RAS under which Aus Co purchases the homeware and kitchen goods from Ireland Co solely cover:

    • the sale or purchase of the homeware and kitchen goods
    • rights and obligations in connection with effecting the purchase of the homeware and kitchen goods.

    This tangible goods transaction/RAS therefore satisfies the category of ‘Low value / low risk sale and purchase tangible trading stock agreements’ on the exclusions list.

    Aus Co is not an OBU.

    Ireland Co is a company that is resident in Ireland for tax purposes.

    Ireland Co does not carry on its business operations through a permanent establishment.

    Aus Co completes the Questions for the transaction/RAS in this example based on its accounting records as shown in the following table. 

    Table 3: Completed entry – Purchase of homeware goods from Ireland Co (Tangible property of a revenue nature)

    Question no.

    Question label

    Response

    1

    Transaction Identifier

    [Transaction ID]

    2

    Related Transaction Identifier(s)

    [Transaction IDs]

    3

    Transaction category

    TPRN

    4

    Is this transaction part of a RAS?

    True

    5

    How many transactions are part of the RAS?

    Moderate

    6

    Australian counterparty name

    [Australian counterparty name]

    7

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

    [ABN or TFN]

    8

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

    Ireland Co

    9

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

    IE

    10

    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?

    False

    11

    Country of permanent establishment counterparty

    na

    12

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

    0

    13

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

    0

    14

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

    False

    15

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

    False

    16

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

    15000000

    17

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

    0

    18

    Average balance of debt interests

    na

    19

    Capitalised interest deducted

    na

    20

    Average balance of debt interests

    na

    21

    Capitalised interest returned

    na

    22

    Book values

    na

    23

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

    False

    24

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

    False

    25

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

    True

    26

    Foreign Currency Reporting Type

    1

    27

    Foreign Currency Code

    USD

    28

    Amount of foreign exchange losses deducted for the transaction/RAS

    na

    29

    Foreign Currency Code

    na

    30

    Amount of foreign exchange gains returned for the transaction/RAS

    na

    31

    Foreign Currency Code

    na

    32

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

    CUP

    33

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

    6

    34

    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

    35

    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

    36

    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

    37

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

    False

    38

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

    True

    39

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

    LVLRSA

    40

    Transaction Comments

    [Comments]

    End of example

     

    Example 3: Purchases of homewares from Irish IRP and currency deferred payment arrangement

    The facts are the same facts as Example 2, except for the following:

    • For two of the eight shipments Aus Co failed to satisfy the payment of the purchase price in accordance with the terms of the procurement and sale agreements. For these two shipments Aus Co made payment of the purchase price 100 days after the date of billing.
    • Aus Co completes the Questions for the transaction/RAS in this example based on its accounting records as shown in the following table. 
    Table 4: Completed entry – Purchase of homeware goods from Ireland Co (Tangible property of a revenue nature) (Deferred foreign currency payment arrangement)

    Question no.

    Question label

    Response

    1

    Transaction Identifier

    [Transaction ID]

    2

    Related Transaction Identifier(s)

    [Transaction IDs]

    3

    Transaction category

    TPRN

    4

    Is this transaction part of a RAS?

    True

    5

    How many transactions are part of the RAS?

    Moderate

    6

    Australian counterparty name

    [Australian counterparty name]

    7

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

    [ABN or TFN]

    8

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

    Ireland Co

    9

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

    IE

    10

    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?

    False

    11

    Country of permanent establishment counterparty

    na

    12

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

    0

    13

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

    0

    14

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

    False

    15

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

    False

    16

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

    15000000

    17

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

    0

    18

    Average balance of debt interests

    na

    19

    Capitalised interest deducted

    na

    20

    Average balance of debt interests

    na

    21

    Capitalised interest returned

    na

    22

    Book values

    na

    23

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

    False

    24

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

    False

    25

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

    True

    26

    Foreign Currency Reporting Type

    2

    27

    Foreign Currency Code

    na

    28

    Amount of foreign exchange losses deducted for the transaction/RAS

    na

    29

    Foreign Currency Code

    na

    30

    Amount of foreign exchange gains returned for the transaction/RAS

    na

    31

    Foreign Currency Code

    na

    32

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

    CUP

    33

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

    6

    34

    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

    35

    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

    36

    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

    37

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

    False

    38

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

    True

    39

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

    LVLRSA

    40

    Transaction Comments

    [Comments]

     

    Table 5: Completed entry – Foreign currency deferred payment arrangement for purchase of Tangible Trading Stock (FCDPTTS)

    Question no.

    Question label

    Response

    1

    Transaction Identifier

    [Transaction ID]

    2

    Related Transaction Identifier(s)

    na

    3

    Transaction category

    FCDPTTS

    4

    Is this transaction part of a RAS?

    False

    5

    How many transactions are part of the RAS?

    na

    6

    Australian counterparty name

    [Australian counterparty name]

    7

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

    [ABN or TFN]

    8

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

    Ireland Co

    9

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

    IE

    10

    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?

    False

    11

    Country of permanent establishment counterparty

    na

    12

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

    0

    13

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

    0

    14

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

    False

    15

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

    False

    16

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

    0

    17

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

    0

    18

    Average balance of debt interests

    na

    19

    Capitalised interest deducted

    na

    20

    Average balance of debt interests

    na

    21

    Capitalised interest returned

    na

    22

    Book values

    na

    23

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

    False

    24

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

    False

    25

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

    na

    26

    Foreign Currency Reporting Type

    na

    27

    Foreign Currency Code

    na

    28

    Amount of foreign exchange losses deducted for the transaction/RAS

    150000

    29

    Foreign Currency Code

    USD

    30

    Amount of foreign exchange gains returned for the transaction/RAS

    200000

    31

    Foreign Currency Code

    USD

    32

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

    CUP

    33

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

    6

    34

    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?

    na

    35

    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?

    na

    36

    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?

    na

    37

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

    na

    38

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

    False

    39

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

    na

    40

    Transaction Comments

    [Comments]

     

    End of example
      Last modified: 14 Jun 2019QC 56216