Appendixes – local file and master file | Australian Taxation Office

Appendix A: Glossary

Table 18: 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
Controlled transactions	Dealings with an International related parties (IRPs)
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 or section 820-930 of the ITAA 1997
Foreign entity	Any entity which is not an Australian resident for tax purposes
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 related party dealings (IRPD)	See What is an IRP and IRPD?
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

Table 19: IRPDs in tangible property of a revenue nature
Code	Value
TPRN	Tangible property of a revenue nature

Table 20: IRPD service arrangements
Code	Value
TRS	Treasury-related services
MAS	Management and administration services
INSERV	Insurance services
REINSERV	Reinsurance services
RD	Research and development services
SAM	Sales and marketing services
SITS	Software and IT services
TS	Technical services
LS	Logistics services
AM	Asset management services
OS	Other services

Table 21: IRPD use rights
Code	Value
RUIP	Rights to use IP
ORSR	Other rights to use, supply or receive where consideration is royalty under section 6(1) of the ITAA 1936
LF	Licence fees
RRP	Rent of real property
HLPE	Hire or lease of plant or equipment
LHORP	Lease or hire of other property or rights

Table 22: IRPD share-based employment remuneration
Code	Value
SBER	Share based employment remuneration

Table 23: Other revenue (non-financial) IRPDs
Code	Value
CCA	Cost contribution arrangement
ORIRPD	Other revenue IRPDs

Table 24: IRPD derivative transactions
Code	Value
CCIRS	Cross currency interest rate swap
CDCSFFO	Currency derivative (not cross currency interest rate swap), including currency swap, forward, future or option
FFIRS	Fixed for floating interest rate swap (not cross currency)
OIRD	Other interest rate derivative (not cross currency)
CDS	Credit default swap
AS	Asset swap
CDCS	Commodity derivative, including commodity swap, forward, future or option
OD	Other derivative

Table 25: IRPD debt interests (including ordinary loans and borrowings)
Code	Value
OBL	Ordinary borrowings / loans (excluding trade financing)
TFIN	Trade financing
BND	Bonds
PNOT	Promissory notes
CNTDI	Convertible notes that are debt Interests
CSTDI	Convertible shares that are debt Interests
RPSDI	Redeemable preference shares that are debt Interests
OKDI	Other kinds of debt Interests

Table 26: IRPD debt factoring or debt securitisation
Code	Value
IDF	Inward debt factoring
ODF	Outward debt factoring
IDSEC	Inward debt securitisation
ODSEC	Outward debt securitisation

Table 27: Other kinds of IRPDs of a financial nature
Code	Value
GILDI	Guarantee or indemnity of liability under debt Interest
GIOKL	Guarantee or indemnity of other kind of liability
IN	Insurance
REIN	Reinsurance
OFD	Other financial dealings

Table 29: IRPDs involving disposal or acquisition of intangible property or rights of a non-revenue (capital) nature
Code	Value
ASIP	Assignment of IP
IOSH	Issue of ordinary shares
AOSH	Assignment of ordinary shares
IEIOOS	Issue of equity interest other than ordinary shares
AQIOS	Assignment of equity interest other than ordinary Shares
ASSD	Assignment of debts
ASSL	Assignment of liabilities
ASSBC	Assignment of benefit of contracts (excluding assignment of equity interests, debts or IP)
ASSOPR	Assignment of other intangible property or rights

Table 30: Foreign Exchange IRPDs
Code	Value
FCDSTTS	Foreign currency deferred payment arrangement for sale of Tangible Trading Stock
FCDPTTS	Foreign currency deferred payment arrangement for purchase of Tangible Trading Stock
FCDAPS	Foreign currency deferred payment arrangement for provision of Services
FCDAAS	Foreign currency deferred payment arrangement for acquisition of Services
FCDRRP	Foreign currency deferred payment arrangement for rent of real property to IRP
FCDRRPI	Foreign currency deferred payment arrangement for rent of real property from IRP
FCDHLP	Foreign currency deferred payment arrangement for hire or lease of plant or equipment to IRP
FCDHLPE	Foreign currency deferred payment arrangement for hire or lease of plant or equipment from IRP
FCDSBER	Foreign currency deferred payment arrangement for share based employment recharge to IRP
FCDSBERI	Foreign currency deferred payment arrangement for share based employment recharge from IRP

Table 31: Appendix C
Code	Value
APPC	Apportionment of costs
APPI	Apportionment of Income
CUP	Comparable uncontrolled price method
CCA	Cost-contribution arrangement
CP	Cost-plus method
FMUAC	Fixed mark-up applied to cost
FPRP	Fixed percentage of resale price
MC	Marginal costing
PS	Profit split method
RPM	Resale price method
TNM	Transactional net margin method
TNMW	Transactional net margin method (whole-of-entity)
OTH	Other arm's length methods
NON	None
UNKT	Unknown (transfer pricing method)
CPR	Cost Price
DVAL	Directors valuation
DCF	Discounted cash flow
IVAL	Independent valuation
NCON	Nil consideration
QMRP	Quoted market price
WDVAL	Written-down value
OM	Other methods
UNKC	Unknown (capital asset pricing method)

Table 32: Appendix D
Code	Value
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%
7	Simplified transfer pricing record keeping (materiality)
8	Simplified transfer pricing record keeping (small taxpayers)
9	Simplified transfer pricing record keeping (distributors)
10	Simplified transfer pricing record keeping (intra-group services)
11	Simplified transfer pricing record keeping (management & administration services)
12	Simplified transfer pricing record keeping (technical services)
13	Simplified transfer pricing record keeping (low level loans – inbound)
14	Simplified transfer pricing record keeping (low level loans – outbound)
15	Green Zone (PCG 2017/1)
16	Green Zone (PCG 2017/4)

Table 33: Appendix E
Code	Value
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 – inbound)
STPRKLLO	Simplified transfer pricing record keeping (low level loans – outbound)
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