Instructions to complete the aggregate amount of transactions or dealings with international related parties.
International dealings schedule for overseas transactions or thin capitalisation
You must complete this section (and, if required, the International dealings schedule 2023) based on your circumstances as a CCIV sub-fund.
The information requested in this section (and, if required, the International dealings schedule 2023) is for information gathering purposes only. The information you provide is not indicative of any interpretive position of the trustee or the Commissioner about the application of the tax laws to CCIV sub-fund trusts. Trustees or advisers of CCIV sub-fund trusts may contact the ATO for guidance on the application of these laws to their particular circumstances.
You must complete an International dealings schedule 2023, if:
- you had overseas interest expenses
- you had royalty expenses overseas
- you answer Yes to either of the following 2 questions
International related parties aggregate amount
Was the aggregate amount of your transactions or dealings with international related parties (including the value of any property or service transferred or the balance of any loans) greater than $2 million?
Indicate Yes or No in the space provided, as appropriate to your circumstances.
If you answer Yes, you must complete an International dealings schedule 2023.
For more information on international related party dealings, see Section A of the International dealings schedule instructions 2023.
Did the thin capitalisation provisions affect you?
Indicate yes or no in the space provided, as appropriate for your circumstances.
If you answer Yes, you must complete an International dealings schedule 2023.
More information on thin capitalisation see, Section D of the International dealings schedule instructions 2023.
Interest expenses overseas
Enter the amount of interest expenses the CCIV sub-fund trust paid to non-residents.
You must generally withhold an amount of tax (withholding tax) from:
- interest paid or payable to non-residents
- interest derived by a resident through an overseas branch.
You must remit these withheld amounts to us. You cannot claim a deduction for the interest expenses unless you have remitted relevant withholding tax to the Commissioner.
Do not include amounts of actual or deemed payments to members that are AMIT dividend, interest and royalty (DIR) payments.
Royalty expenses overseas
Enter the amount of royalty expenses the CCIV sub-fund trust paid to non-residents.
You must generally withhold an amount of tax (withholding tax) from:
- royalties paid or payable to non-residents
- royalties derived by a resident through an overseas branch.
You must remit this amount to us. You cannot claim a deduction for the royalty expenses unless you have remitted any relevant withholding tax to the Commissioner.
Do not include amounts of actual or deemed payments to members that are AMIT DIR payments.
Record keeping
Keep a record of:
- names and addresses of recipients
- amounts paid
- the nature of the benefit derived, for example, a copy of the royalty agreement
- details of tax withheld where applicable, and the date it was remitted to us.
Find out about requirements for Record keeping for overseas transactions.
Continue to: Transactions with specified countries