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  • Appendices

    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: 26 Jun 2019QC 59433