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Question 5

Last updated 27 May 2020

The intent of this question is to identify whether the taxpayer has any international related party dealings involving tangible property of a revenue nature, including trading stock and raw materials, and if so, to quantify those dealings and to ascertain the extent to which the taxpayer has transfer pricing documentation to support those dealings.

The dollar amounts or values asked for in this question are all based on your accounting records.

The definition of trading stock in Division 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.

Internal trading stock transfers to or from your own branch operations should instead be included at question 18 of the schedule.

If you had related party dealings involving tangible property of a revenue nature, including trading stock and raw materials, answer Yes at A item 5 and complete the required fields.

At C, write the amount of your gross purchases or expenditure for tangible property of a revenue nature, including trading stock and raw materials obtained from international related party dealings.

At D, write the amount of your gross sales or revenue from tangible property of a revenue nature, including trading stock and raw materials provided to international related parties.

These amounts will typically be included in trading account items, and will include partially finished goods.

At E, write the Appendix 5 code for the principal arm's length pricing method used to value intangible property of a revenue nature, including stock in trade and raw materials transactions.

At F, write the Appendix 9 code for the percentage of these dealings involving tangible property of a revenue nature, including trading stock and raw materials, for which you have documentation.

Percentage of dealings with documentation refers to the aggregate dollar amount of transactions reported at this question for which you have relevant documentation expressed as a percentage of total dollar value of transactions reported at this question. If you applied one of the simplified record-keeping options in the Practical Compliance Guideline PCG 2017/2 Simplified transfer pricing record-keeping options for these dealings involving tangible property of a revenue nature, including trading stock and raw materials, write code 7 at F.

QC62599