Local file/master file 2018

Detailed design

We have developed a local file / master file XML schema (LCMSF) and associated validation rules to enable reporting entities to submit their local file / master file to the ATO.

The design of the LCMSF allows for the local file's three components and the master file to be submitted independently of each other. The LCMSF also contains a Country-by-Country (CbC) report notification section to allow reporting entities to provide details of their global parent entity or surrogate parent entity for us to anticipate exchange from the relevant foreign jurisdictions. However, entities lodging the CbC report directly with us must lodge the CbC report separately in accordance with the OECD XML schema and User GuideExternal Link.

The 2018 LCMSF comprises the following sections:

statement information for basic information relating to the statement being submitted
entity information about the reporting entity, the global parent entity (where applicable) and declarations
master file
CbC report notification
local file, including the short form, Part A and Part B
Intermediary information (including Intermediary)

You should also refer to the Appendixes for various relevant codes used for reporting as part of the lodgment.

On this page:

Electronic lodgment
Message structure table

Electronic lodgment

How to lodge

CbC statements (the CbC report, master file and local file) must be lodged via one of the following ATO approved channels:

Business Portal / Online services for tax agents using the File Transfer Facility (not via mail message)
Standard Business ReportingExternal Link (SBR) using SBR-enabled software

CbC statements must be submitted via the above channels using a validly generated XML file, otherwise the lodgment will not be considered valid. This XML file is generated by your business management software (that is tax reporting / accounting software) using the ATO provided XML schema. Additionally, the XML file must adhere to our validation rules and other technical requirements.

You may need to make enquires with your software provider as to whether they support lodging CbC reporting statements to the ATO.

If the valid lodgments are not received by the due date, increased failure to lodge penalties may be imposed. You may request a deferral by emailing CbCReporting@ato.gov.au if you have difficulty in meeting the due date.

For more information on electronic lodgment, visit our Online services page.

For more information on the XML schema, validation rules and other technical documentation, visit our Significant Global Entity ObligationExternal Links (SGEO) page on the SBR websiteExternal Link and the CbC software developersExternal Link site.

Amendments

The LCMSF does not support delta amendments. When making an amendment to a previously lodged statement (or part thereof), please ensure that all the data related to that statement (or part thereof) is resubmitted along with the corrected data.

Cancelling Lodgments

If you would like to cancel a lodgment that has been submitted, please email the CbC Reporting Team.

Attachments

No particular attachment naming convention is enforced, with the exception that:

filenames must be unique
cannot exceed 255 characters
cannot contain the following illegal characters: <, >, :, ", /, \, |, ?, *.
filenames are not case sensitive

There is a maximum of 500 attachments per lodgment, where the size of any single attachment cannot exceed 20Mb. All attachments embedded in the XML file must also be referenced at the appropriate LCMSF element depending on the type of attachment.

Table 3 outlines the types of attachments that are accepted. Multiple attachments can be embedded for each type:

Table 3: Supported attachment types
Attachment Code	Attachment Type
MSTR	Master File
LFSF	Local File – Short Form
LFPBI	IRP Agreement
LFPBA	APA
LFPBR	Ruling
LFPBF	Financial Statements

Table 4 lists the supported attachment formats that can be embedded within the XML file (using BASE64 encoding). Attachments cannot contain active content, i.e. macros, JavaScript, etc.

Table 4: Supported attachment formats
File Extension	File type
DOC	Microsoft Word Binary File Format
DOCX	Office Open XML
XLS	Excel Binary File Format
XLSX	Office Open XML
PDF	Portable Document Format
ODT	OpenDocument Text
ODS	OpenDocument Spreadsheet

Message structure table

The following tables provide an overview of the 2018 LCMSF. The question IDs relate to the associated elements provided in the message structure tableExternal Link (MST) provided to digital service providers.

Reporting Party Information

Table 5: Statement information
Question	Question ID	Valid values	Comments
Amendment	LCMSF1	True/False	Mandatory question Indicates whether this lodgment is an amendment to a previous lodgment Amended lodgments do not include those lodgments where additional statements (or parts thereof) are being lodged for the first time

The Reporting Entity Declaration is required if the statement is submitted by the reporting entity (that is the intermediary details have not been provided).

Table 6: Reporting entity declaration
Question	Question ID	Valid values	Comments
Reporting Entity declaration statement accepted indicator	LCMSF55	True/False	I declare that the information transmitted in this report is to my knowledge true and correct and that I am authorised to make this declaration.
Reporting Entity declaration signature date	LCMSF56	YYYY–MM–DD	The actual date on which the declaration is signed by the reporting entity
Reporting Entity declaration signatory identifier	LCMSF57	A user login, a full name or an email address	Maximum of 200 characters

Table 7: Reporting period
Question	Question ID	Valid values	Comments
Reporting period start date	LCMSF142	YYYY–MM–DD	Mandatory question The start date of the tax year of the reporting entity
Reporting period end date	LCMSF143	YYYY–MM–DD	Mandatory question The end date of the tax year of the reporting entity

Entity information

Reporting entity information

Table 8: Reporting entity information
Question	Question ID	Valid values	Comments
Reporting entity ABN	LCMSF7	ABN	A valid TFN
Reporting entity TFN	LCMSF65	TFN	A valid ABN
Reporting entity name	LCMSF8	Legal name of the entity	Mandatory question Maximum of 200 characters
Reporting entity email	LCMSF21	Email address	Mandatory question Maximum of 200 characters Must be a valid email address
Reporting entity phone	LCMSF22	Mobile or landline	Mandatory question Maximum of 16 characters
Is the reporting entity the head entity of a tax consolidated group?	LCMSF15	True/False	Mandatory question
Is the reporting entity the provisional head entity of a Multiple entry consolidated (MEC) group?	LCMSF16	True/False	Mandatory question
Is the reporting entity an Offshore banking unit (OBU)?	LCMSF61	True/False	Mandatory question

Global parent entity information

Table 9: Global parent entity information
Question	Question ID	Valid values	Comments
Is the Reporting Entity the Global Parent Entity?	LCMSF66	True/False	Mandatory question If True, go to Master File section If False, go to LCMSF11
Global Parent Entity name	LCMSF11	Legal name of the entity	Must be provided if LCMSF66 is False Maximum of 200 characters
Global Parent Entity tax jurisdiction	LCMSF12	Country codeExternal Link	Must be provided if LCMSF66 is False
Global Parent Entity ABN	LCMSF9	ABN	If LCMSF12 is "AU" (Australia), either a valid ABN or TFN is required
Global Parent Entity TFN	LCMSF10	TFN	If LCMSF12 is "AU" (Australia), either a valid ABN or TFN is required
Global Parent Entity TIN	LCMSF194	TIN	If LCMSF12 is not "AU" (Australia), a TIN is required

Master file

Table 10: Master file lodgment criteria
Question	Question ID	Valid values	Comments
Does this submission include details regarding your master file?	LCMSF138	True/False	Mandatory question If False, go to CbC report section If True, go to LCMSF81
Has the Commissioner, by notice in writing, exempted you from providing the master file for this reporting period?	LCMSF81	True/False	If True, go to CbC report section If False, go to LCMSF121
Have you been granted a replacement reporting period for the master file?	LCMSF121	True/False	If True, replacement reporting period dates must be provided If False, go to LCMSF196
Replacement reporting period start date	LCMSF122	YYYY–MM–DD	The start date of the replacement reporting period
Replacement reporting period end date	LCMSF123	YYYY–MM–DD	The end date of the replacement reporting period
How is the master file for your global group being lodged?	LCMSF196	1, 2	1 = Lodgment to the ATO via the Reporting Entity 2 = Lodgment to the ATO via another entity
Is your lodgment of the master file also on behalf of other entities forming part of your global accounting group (outside your tax consolidated group)?	LCMSF76	True/False	Required if LCMSF196 = 1 If True, LCMSF77 or LCMSF78 must be provided
ABN(s) of the entities	LCMSF77	ABN	Either valid ABNs or TFNs must be provided
TFN(s) of the entities	LCMSF78	TFN	Either valid ABNs or TFNs must be provided
Please confirm that you have attached the master file	LCMSF124	True/False	Required if LCMSF196 = 1 and must be True The master file should meet the information requirements as outlined in Annex I of the OECD GuidanceExternal Link
Filename(s) for the Master File	LCMSF197	Filename including extension	Required if LCMSF196 = 1 and at least one filename must be provided See Attachments
ABN of the entity	LCMSF19	ABN	Applicable if LCMSF196 = 2 Either a valid ABN or TFN is required
TFN of the entity	LCMSF20	TFN	Applicable if LCMSF196 = 2 Either a valid ABN or TFN is required

CbC report notification

A CbC report notification may be submitted with a master file or local file or as a stand-alone lodgment.

Table 11: CbC report - notification
Question	Question ID	Valid values	Comments
Does this submission include details regarding your CbC report?	LCMSF139	True/False	Mandatory question If False, go to Local file section If True, go to LCMSF69
Has the Commissioner, by notice in writing, exempted you from providing the CbC report for this reporting period?	LCMSF69	True/False	If True, go to Local file section If False, go to LCMSF125
Have you been granted a replacement reporting period for the CbC report?	LCMSF125	True/False	If True, replacement reporting period dates must be provided If False, go to LCMSF114
Replacement reporting period start date	LCMSF126	YYYY–MM–DD	The start date of the replacement reporting period
Replacement reporting period end date	LCMSF127	YYYY–MM–DD	The end date of the replacement reporting period
Are the details you are submitting regarding the CbC report also on behalf of other entities forming part of your global accounting group but outside your tax consolidated group?	LCMSF114	True/False	If True, a valid ABN or TFN must be provided If False, go to LCMSF199
ABN(s) of the entities	LCMSF115	ABN	Either valid ABNs or TFNs must be provided
TFN(s) of the entities	LCMSF116	TFN	Either valid ABNs or TFNs must be provided
How is the CbC report for your global group being lodged?	LCMSF199	1, 2, or 3	1 = Lodgment to the ATO via the Reporting Entity 2 = Lodgment to the ATO via another entity 3 = Lodgment via an overseas jurisdiction
Are you filing the CbC report as a surrogate parent entity with the filing intended to meet a CbC reporting obligation in other jurisdictions?	LCMSF140	True/False	Required if LCMSF199 = 1
ABN of the entity	LCMSF72	ABN	Applicable if LCMSF199 = 2 Either a valid ABN or TFN must be provided
TFN of the entity	LCMSF73	TFN	Applicable if LCMSF199 = 2 Either a valid ABN or TFN must be provided
Foreign Entity Name	LCMSF71	Legal Name of Entity	Required if LCMSF199 = 3
Foreign Entity TIN	LCMSF201	TIN	Required if LCMSF199 = 3
Foreign Entity Tax Jurisdiction	LCMSF74	Country codeExternal Link	Required if LCMSF199 = 3

Local file

Table 12: Local file
Question	Question ID	Valid values	Comments
Does this submission include details regarding your local file?	LCMSF137	True/False	Mandatory question If False, go to Intermediary section If True, go to LCMSF117
Has the Commissioner, by notice in writing, exempted you from providing the local file for this reporting period?	LCMSF117	True/False	If True, go to Intermediary section If False, go to LCMSF119
Which parts of the local file are you lodging in this submission?	LCMSF119	Local file – short form, Local file – Part A, Local file – Part B	Required if LCMSF137 is True and LCMSF117 is False At least one value must be provided
Is your lodgment of the Local File - Part A being made as part of the ‘Administrative Solution’?	LCMSF68	True/False	Must be provided if LCMSF119 = Local File - Part A Administrative solution
Have you been granted a replacement reporting period for the local file?	LCMSF120	True/False	If True, replacement reporting period dates must be provided
Replacement reporting period start date	LCMSF13	YYYY–MM–DD	The start date of the replacement reporting period
Replacement reporting period end date	LCMSF14	YYYY–MM–DD	The end date of the replacement reporting period

Local file – short form

This section must be completed if you have selected that you will be providing the local file – short form as part of this submission at LCMSF119.

Table 13: Local file – short form
Question	Question ID	Valid values	Comments
Did you engage in IRP transactions or dealings listed on the short form exceptions list for the reporting period?	LCMSF27	True/False	Mandatory question
Did you have less than $2m in aggregate IRPDs for the reporting period?	LCMSF28	True/False	Mandatory question What is an IRP and IRPD?
Did you meet the criteria for the Small taxpayers STPRK option for the reporting period?	LCMSF29	True/False	Mandatory question Small taxpayers STPRK option
Did you meet the criteria for the Materiality STPRK option for the reporting period?	LCMSF30	True/False	Mandatory question Materiality STPRK option
Please confirm that you have attached the Local File - Short Form	LCMSF82	True/False	Mandatory question Must be True
Filename(s) for the Short Form	LCMSF204	Filename including extension	Mandatory question At least one filename must be provided See Attachments

Local file – Part A

This section must be completed if you have selected that you will be providing the local file – Part A as part of this submission at LCMSF119.

Table 14: Local file – Part A
Question	Question ID	Valid values	Comments
Transaction Identifier	LCMSF31	Number	Mandatory question Incrementing number for each transaction that is used to link Part A and Part B
Related Transaction Identifier(s)	LCMSF206	Number	See here.
Transaction type	LCMSF32	Transaction category	Mandatory question See Appendix B
Is this transaction part of a Relevant Agreement Series (RAS)?	LCMSF33	True/False	Mandatory question See Local file – Part B: Guidance on providing International Related Party agreements
How many transactions are part of the RAS?	LCMSF35	Low / Moderate / High	Required if LCMSF33 = True Low = 1–5 Moderate = 6–50 High = 51 or more
Australian counterparty name	LCMSF207	Legal Name of the Entity	Mandatory question Maximum of 200 characters
Australian counterparty ABN	LCMSF83	ABN	Either a valid ABN or TFN is required
Australian counterparty TFN	LCMSF84	TFN	Either a valid ABN or TFN is required
Non-resident counterparty name	LCMSF37	Legal name of the entity	Mandatory question Maximum of 200 characters
Non-resident counterparty tax jurisdiction	LCMSF38	Country codeExternal Link	Mandatory question
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?	LCMSF208	True/False	Mandatory question
Country of permanent establishment of non-resident counterparty	LCMSF209	Country codeExternal Link	Required if LCMSF208 is True
Amount of consideration paid (of a capital nature for income tax purposes) for the transaction	LCMSF39	$XX,XXX,XXX,XXX	Mandatory question
Amount of consideration received (of a capital nature for income tax purposes) for the transaction	LCMSF40	$XX,XXX,XXX,XXX	Mandatory question
Was non-monetary consideration provided (of a capital nature for income tax purposes) for the transaction?	LCMSF85	True/False	Mandatory question
Was non-monetary consideration obtained (of a capital nature for income tax purposes) for the transaction?	LCMSF86	True/False	Mandatory question
Amount of expenditure (not of a capital nature for income tax purposes) for the transaction	LCMSF41	$XX,XXX,XXX,XXX	Mandatory question
Amount of revenue (not of a capital nature for income tax purposes) for the transaction	LCMSF42	$XX,XXX,XXX,XXX	Mandatory question
Average balance of debt interests held	LCMSF210	$XX,XXX,XXX,XXX	Applicable only if Transaction Category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI or OKDI Mandatory if LCMSF211 is provided Must not be provided if LCMSF212 and LCMSF213 is present
Capitalised interest deducted	LCMSF211	$XX,XXX,XXX,XXX	Applicable only if Transaction Category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI or OKDI Mandatory if LCMSF210 is provided Must not be provided if LCMSF212 and LCMSF213 is present
Average balance of debt interests issued	LCMSF212	$XX,XXX,XXX,XXX	Applicable only if Transaction Category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI or OKDI Mandatory if LCMSF213 is provided Must not be provided if LCMSF210 and LCMSF211 is present
Capitalised interest returned	LCMSF213	$XX,XXX,XXX,XXX	Applicable only if Transaction Category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI or OKDI Mandatory if LCMSF212 is provided Must not be provided if LCMSF210 and LCMSF211 is present
Book values	LCMSF214	$XX,XXX,XXX,XXX	Mandatory if Transaction Category is IDF, ODF, IDSEC or ODSEC
Was non-monetary consideration provided (not of a capital nature for income tax purposes) for the transaction	LCMSF44	True/False	Mandatory question
Was non-monetary consideration obtained (not of a capital nature for income tax purposes) for the transaction	LCMSF45	True/False	Mandatory question
Did you enter into a deferred foreign currency payment arrangement in relation to this transaction	LCMSF215	True/False	See FX Guidance for Year 2 Applicable only if Transaction Category is TPRN, TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, OS, RRP, HLPE or SBER
Foreign Currency Reporting Type	LCMSF216	1, 2	Required if LCMSF215 is True 1 = Regular / short term foreign currency deferred payment arrangements 2 = Irregular or longer term foreign currency deferred payment arrangements
Foreign Currency Code	LCMSF217	Currency CodesExternal Link	Required if LCMSF216 is 1
Amount of foreign exchange losses deducted for the transaction	LCMSF87	$XX,XXX,XXX,XXX	Applicable if LCMSF215 is False, or Blank, or for Transaction Categories FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER or FCDSBERI Required if LCMSF219 is provided
Foreign Currency Code	LCMSF219	Currency CodesExternal Link	Applicable if LCMSF215 is False, or Blank, or for Transaction Categories FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER or FCDSBERI Required if LCMSF87 is provided
Amount of foreign exchange gains returned for the transaction	LCMSF43	$XX,XXX,XXX,XXX	Applicable if LCMSF215 is False, or Blank, or for Transaction Categories FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER or FCDSBERI Required if LCMSF221 is provided
Foreign Currency Code	LCMSF221	Currency CodesExternal Link	Applicable if LCMSF215 is False, or Blank, or for Transaction Categories FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER or FCDSBERI Required if LCMSF43 is provided
What transfer pricing / capital asset pricing methodology has been applied to this transaction?	LCMSF46	TP method / CAP method	Mandatory question See Appendix C
What level of transfer pricing documentation has been prepared for this transaction?	LCMSF47	TP Documentation / STPRK codes	Mandatory question Both TP Documentation and STPRK codes can be provided for one transaction When the Transaction Category is TPRN, RUIP, ORSR, LF, RRP, HLPE, LHORP, SBER, CCA or ORIRPD values cannot be 10, 11, 12, 13, or 14. When Transaction Category is TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, or OS values cannot be 13 or 14. When Transaction Category is CCIRS, CDCSFFO, FFIRS, OIRD, CDS, CDCS, AS, OD, RPRT, PLEQ, OTPRTY, ASIP, IOSH, AOSH, IEIOOS, AQIOS, ASSD, ASSL, ASSBC, ASSOPR values cannot be 8, 9, 10, 11, 12, 13, or 14 When Transaction Category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI or OKDI values cannot be cannot be 8, 9, 10, 11, or 12 When Transaction Category is IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN or OFD values cannot be 8, 9, 10, 11, 12, 13, or 14 See Appendix D
Has the special short term tenor rule for ordinary borrowings and ordinary loans been applied to this transaction?	LCMSF88	True/False	Mandatory question Must be false, where the Transaction Category is TPRN, TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, OS, RUIP, ORSR, LF, RRP, HLPE, LHORP, SBER, CCA, ORIRPD, CCIRS, CDCSFFO, FFIRS, OIRD, CDS, CDCS, AS, OD, IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN, OFD, RPRT, PLEQ, OTPRTY, ASIP, IOSH, AOSH, IEIOOS, AQIOS, ASSD, ASSL, ASSBC or ASSOPR
Has the special short term tenor rule for short term derivatives been applied to this transaction?	LCMSF128	True/False	Mandatory question Must be false, where the Transaction Category is TPRN, TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, OS, RUIP, ORSR, LF, RRP, HLPE, LHORP, SBER, CCA, ORIRPD, IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN, OFD, RPRT, PLEQ, OTPRTY, ASIP, IOSH, AOSH, IEIOOS, AQIOS, ASSD, ASSL, ASSBC, ASSOPR, OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI or OKDI
Has the special short term tenor rule for FX derivatives been applied to this transaction?	LCMSF129	True/False	Mandatory question Must be false, where the Transaction Category is TPRN, TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, OS, RUIP, ORSR, LF, RRP, HLPE, LHORP, SBER, CCA, ORIRPD, IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN, OFD, RPRT, PLEQ, OTPRTY, ASIP, IOSH, AOSH, IEIOOS, AQIOS, ASSD, ASSL, ASSBC, ASSOPR, OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI or OKDI
Is this transaction an OB Activity?	LCMSF63	True/False	Can only be True when LCMSF32 is True and the Transaction Category is TPRN, TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, OS, RUIP, ORSR, LF, RRP, HLPE, LHORP, CCA, ORIRPD, CCIRS, CDCSFFO, FFIRS, OIRD, CDS, CDCS, AS, OD, OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI, OKDI, IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN, or OFD Must be false where, Transaction Category is RPRT, PLEQ, OTPRTY, ASIP, IOSH, AOSH, IEIOOS, AQIOS, ASSD, ASSL, ASSBC, ASSOPR, or SBER
Is this transaction covered by an exclusion list category?	LCMSF48	True/False	Mandatory question Must be false where, Transaction Category is RUIP, ORSR, LF, RRP, HLPE, LHORP, CCIRS, CDCSFFO, FFIRS, OIRD, CDS, CDCS, AS, OD, SBER, IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN, OFD, RPRT, PLEQ or OTPRTY
What exclusion list category applies to this transaction?	LCMSF49	Exclusion list category code	Required if LCMSF48 is True When Transaction Category is TPRN, CCA, ORIRPD valid values are RUESA or LVLRSPT When Transaction Category is TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, or OS valid values are STPRKIGS, STPRKMAS, STPRKTS, RUESA or LVLRSA When Transaction Category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI, OKDI, valid values are STPRKLLI or STPRKLLO When Transaction Category is ASIP, IOSH, AOSH, IEIOOS, AQIOS, ASSD, ASSL, ASSBC, ASSOPR, valid values are IOS See Appendix E
Transaction Comments	LCMSF222	Text	Maximum of 4096 characters

Local file – Part B

This section is required if you have selected that you will be providing the local file – Part B as part of this submission at LCMSF119.

For more information on providing IRP agreements in the local file – Part B see: Local file – Part B: Guidance on providing International Related Party agreements.

Table 15: Local file – Part B
Question	Question ID	Valid values	Comments
Transaction Identifier	LCMSF50	Number	Mandatory question Incrementing number for each transaction that is used to link Part A and Part B
IRP transfer pricing / capital asset methodology	LCMSF51	TP method / CAP method	Mandatory question See Appendix C
Is the Reporting Entity unable to obtain the transfer pricing methodology the IRP relied upon for this transaction (from the IRP)?	LCMSF130	True/False	Required if LCMSF51 is 'Unknown (TP Method)' or 'Unknown (CAP Method)'
Is there a written agreement or other relevant documentation evidencing the terms of the agreement covering this transaction (as reported in Part A)?	LCMSF52	True/False	Mandatory question If False, go to LCMSF106
Is the Reporting Entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction (as reported at Part A)?	LCMSF64	True/False	Required if LCMSF52 is True If True, go to LCMSF106
Other Transaction IDs covered by the agreement	LCMSF224	Number	Provide the Transaction ID of other transactions (reported in Part A) that are covered by this agreement
Has this written agreement been previously provided to the ATO?	LCMSF53	True/False	Required if LCMSF52 is True and LCMSF64 is false If False, go to LCMSF89
Title of the agreement previously provided to the ATO	LCMSF54	Title of the IRP Agreement	Required if LCMSF53 is True
Year agreement was previously provided to the ATO?	LCMSF90	YYYY	Required if LCMSF53 is True
Please confirm that you have attached the agreement(s) for this transaction	LCMSF89	True/False	Required if LCMSF53 is False and must be True
Filename(s) of IRP Agreement(s)	LCMSF225	Filename(s) of attachment(s)	Required if LCMSF89 is True At least one filename must be provided See Attachments
Since providing the written agreement to the ATO, has the agreement been amended?	LCMSF91	True/False	Required if LCMSF53 is True If False, go to LCMSF106
Have the amended agreements or agreements incorporating the amendments been provided to the ATO?	LCMSF92	True/False	Required if LCMSF91 is True
What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?	LCMSF132	Title of the IRP Agreement (amendment)	Required if LCMSF92 is True
What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?	LCMSF133	YYYY	Required if LCMSF92 is True
Please confirm that you have attached the amendments for previously provided agreements for this transaction	LCMSF131	True/False	Required if LCMSF92 is False and must be True
Filename(s) of the amended agreement(s)	LCMSF226	Filename(s) of attachment(s)	Required if LCMSF131 is True At least one filename must be provided See Attachments
Are there APAs/rulings provided by other jurisdictions for this transaction?	LCMSF106	True/False	Mandatory question If False go to LCMSF107
Which other Transaction IDs does that APA / ruling cover?	LCMSF228	Number	Provide the Transaction ID of other transactions (reported in Part A) that are covered by this APA / Ruling
Has the Reporting Entity previously provided these APAs / rulings to the ATO?	LCMSF134	True/False	Required if LCMSF106 is True If False, go to LCMSF135
What is the year in which the Reporting Entity previously provided these APAs/rulings?	LCMSF136	YYYY	Required if LCMSF134 is True
Please confirm that you have attached the relevant APAs/rulings for this transaction	LCMSF135	True/False	Required if LCMSF134 is False and must be True
Filename(s) of the APAs / Rulings	LCMSF229	Filename(s) of attachment(s)	Required if LCMSF135 is True At least one filename must be provided See Attachments
Please confirm that you have attached the Reporting Entity’s financial accounts for the reporting period	LCMSF107	True/False	Mandatory question
Filename(s) for the financial statements	LCMSF230	Filename(s) of attachment(s)	Required if LCMSF107 is True At least one filename must be provided See Attachments

Intermediary

Intermediary information

This section is only required if the form is submitted by an intermediary (for example, a tax agent) on behalf of the reporting entity.

Table 16: Intermediary information
Question	Question ID	Valid values	Comments
Intermediary ABN	LCMSF2	ABN	Must be a valid ABN
Intermediary name	LCMSF3	Name of the intermediary	Maximum of 200 characters
Intermediary email	LCMSF4	Email address	Maximum of 200 characters Must be a valid email address
Intermediary phone	LCMSF5	Mobile or landline	Maximum of 16 characters
Tax agent number (TAN)	LCMSF6	TAN	Must be a valid TAN

Intermediary declaration

Required if the statement is submitted by an intermediary.

Table 17: Intermediary declaration
Question	Question ID	Valid values	Comments
Intermediary declaration statement accepted indicator	LCMSF58	True/False	I declare that: All of the information I have provided to the agent for the preparation of this document is to my knowledge true and correct I authorise the agent to give this document to the Commissioner of Taxation.
Intermediary declaration signature date	LCMSF59	YYYY–MM–DD	The actual date on which the declaration is signed by the intermediary
Intermediary declaration signatory identifier	LCMSF60	A user login, a full name or an email address	Maximum of 200 characters

Appendixes

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

Appendix B: Transaction categories

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 28: IRPDs involving disposal or acquisition of tangible property of a non-revenue (capital) nature
Code	Value
RPRT	Real property
PLEQ	Plant or equipment
OTPRTY	Other tangible property

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

Appendix C: TP method / CAP method

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)

Appendix D: TP documentation codes / STPRK options

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)

Appendix E: Exclusion list

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

Last modified: 15 Nov 2018QC 56215