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Last updated 12 July 2023

Methodology

IRPD statistics is based on cleansed IRPD data as at 16 February 2023, combining data from processed IDS and LFPA lodgments.

The IRPD statistics in IRPD statistics 2020–21 reflect the most complete picture of total IRPDs.

To meet privacy and confidentiality requirements, some items may be aggregated with other items or not included.

Totals in tables and charts may differ from the sum of components due to rounding.

Data sources

International dealings schedule (IDS)

Companies, partnerships, trusts with IRPDs greater than $2 million are required to lodge an IDS. For small business entities there is a higher threshold of the lesser of $5 million or 50% of aggregated turnover. IRPDs are disclosed by IRPD type in the aggregate at Section A of the IDS.

Local file – part A (LFPA)

Country-by-country (CBC) reporting entities are required to lodge country-by-country (CBC) reporting statements, which include the local file.

The local file includes part A (LFPA), which collects IRPD data for individual IRP transactions, at a more detailed level than the aggregated IRPD data in the IDS.

Where statistics are sourced from the LFPA, IRPD data is aggregated to the taxpayer level, to align with IDS reporting.

Administrative solution

The local file administrative solution (admin solution) can be chosen by CBC reporting entities to minimise duplicated IRPD reporting in the IDS and LFPA:

  • If a CBC reporting entity chooses to lodge the LFPA at the same time as the tax return, the IRPD labels at questions 2 to 17 in Section A of the IDS do not need to be completed.
  • Alternatively, if the admin solution is not adopted, CBC reporting entities are generally required to disclose IRPDs in the IDS and the LFPA.

Where a CBC reporting entity has not adopted the admin solution, statistics may be sourced from the IDS or the LFPA, depending on the nature of the IRPD statistic and other considerations.

Hybrid IRPD data

The statistics in IRPD statistics are sourced from curated, hybrid population datasets that combine IRPD data from IDS and LFPA lodgments.

General IRPD statistics

  • Where Section A of the IDS has been completed, IRPD data from the IDS is generally used, instead of the LFPA.
  • Where Section A of the IDS has not been completed, a 'reconstruction' of IDS data for IRPDs (at the taxpayer level) is derived from LFPA data.
Example: general IRPD statistics

Taxpayer

Section A

LFPA

IRPD data source

The Trustee for 123 Trust

 

Reported IDS data

ABC Pty Ltd

 

Reconstructed IDS data

XYZ Limited

 

Reported IDS data

  1. The Trustee for 123 Trust is not required to lodge an LFPA because it is not a CBC reporting entity. The taxpayer's IRPDs are sourced from Section A of the IDS.
  2. ABC Pty Ltd has adopted the local file administrative solution. As the taxpayer has not completed Section A of the IDS, the taxpayer's IRPDs are sourced from reconstructed IDS data derived from the LFPA.
  3. XYZ Limited is a CBC reporting entity that did not adopt the admin solution. The taxpayer disclosed IRPDs in Section A of the IDS, and subsequently lodged an LFPA. The taxpayer's IRPDs are sourced from Section A of the IDS.
End of example

IRPD statistics by jurisdiction

  • Where an LFPA has been lodged, IRPD data from the LFPA is generally used, instead of the IDS. The LFPA collects jurisdictional data for all IRPDs.
  • Where an LFPA has not been lodged, the IRPD data at questions 3 to 4 in Section A of the IDS is used. IDS reporting at these questions is limited to a subset of countries with the highest dollar value of IRPDs.
Example: IRPD statistics by jurisdiction

Taxpayer

Section A

LFPA

Jurisdictional data source

The Trustee for 123 Trust

 

Reported IDS data

ABC Pty Ltd

 

LFPA jurisdictional data

XYZ Limited

 

LFPA jurisdictional data

  1. The Trustee for 123 Trust is not required to lodge an LFPA because it is not a CBC reporting entity. The taxpayer's IRPDs are sourced from Section A of the IDS, noting that the jurisdiction of all IRPDs may not be disclosed.
  2. ABC Pty Ltd has adopted the local file administrative solution. The taxpayer's IRPDs by jurisdiction are sourced from the LFPA.
  3. XYZ Limited is a CBC reporting entity that did not adopt the admin solution. The taxpayer disclosed IRPDs in Section A of the IDS and subsequently lodged an LFPA. The taxpayer's IRPDs by jurisdiction are sourced from the LFPA, which discloses the jurisdiction of all IRPDs.
End of example

Data cleansing and other issues

Data cleansing

Some IRPD data from the LFPA and IDS is affected by a range of reporting and other data integrity issues, the impact of which can be pronounced for the LFPA because IRPDs are reported at the transaction level.

As part of the compilation of IRPD statistics, cleansing procedures have been applied to IRPD data to remediate these issues where possible. Many of the most significant revisions have been applied after consultation with concerned entities.

Examples of data integrity issues include:

  • transcription errors
  • typographical errors involving similar country codes
  • transposition errors which overstate or understate reported IRPDs
  • other unintentional misreporting, where IRPDs haven't been disclosed correctly.

Authorised deposit-taking institutions (ADIs)

IRPD statistics excludes data reported by authorised deposit-taking institutions (ADIs), and foreign banks and branches (banks).

We exclude these records, which relate to a small number of entities, to present a more meaningful overview of statistics for IRPDs.

The dealings reported by these entities can distort or skew IRPD statistics because:

  • banking operations may involve more extensive overseas branch operations than for other industries – the obligation to report, or to not report, dealings between offshore branches and overseas related entities in any particular year may depend on a range of specific factual circumstances and tax rules
  • transitional and special reporting rules apply to local file reporting for banks
  • data quality issues.

Taxation statistics

We also publish IRPD statistics in Taxation statistics 2020–21.

When analysing IRPD statistics, you should be aware that:

  • Taxation statistics also provides non-IRPD statistics from the IDS.
  • Taxation statistics provides limited IRPD statistics from the IDS for the 2012–13 to 2017–18 income years. However, the IRPD statistics in Taxation statistics 2020–21 exclude IRPDs reported in the LFPA, where the majority of IRPDs (by dollar value) are now disclosed.
  • IRPD statistics provides IRPD statistics for the 2015–16 income year onwards. The IRPD statistics in IRPD statistics 2020–21  
    • include IRPDs reported in the IDS and LFPA
    • are curated to minimise the impact of legislative and reporting changes
    • reflect comprehensive data cleansing to address data integrity issues.
     

Other relevant publications

Schedules and instructions

Taxation statistics

Definitions

IDS

International dealings schedule

IRP

International related party

IRPDs

International related party dealings

IRPD type

The type of IRPD based on:

The table below summarises the IRPD types presented in these statistics, along with the LFPA transaction category groupings and IDS questions used.

Table 15: IRPD types and LFPA/IDS data source

IRPD type

LFPA transaction category grouping

IDS question(s)

Tangible property of a revenue nature

IRPDs in tangible property of a revenue nature

Question 5

Royalties and licence fees

IRPD use rights

Question 6

Rent and leasing

IRPD use rights

Question 7

Service arrangements

IRPD service arrangements

Question 8

Interest

IRPD debt interests (including ordinary loans and borrowings)

Question 11a–c

Guarantees

Other kinds of IRPDs of a financial nature

Question 11d

Insurance

Other kinds of IRPDs of a financial nature

Question 11e

Reinsurance

Other kinds of IRPDs of a financial nature

Question 11f

Derivatives

IRPD derivative transactions

Question 9

Other financial

Other kinds of IRPDs of a financial nature

Question 11h

Share-based employee remuneration

IRPD share-based employment remuneration

Question 15

Other IRPDs

Other revenue IRPDs

Question 12

IRP expenditure

Expenditure incurred for IRPDs, including capitalised interest deducted.

For the purposes of these statistics, IRPD expenditure generally excludes:

  • consideration paid for IRPDs of a non-revenue (capital) nature
  • foreign exchange losses deducted for IRPDs.

IRP revenue

Revenue earned or derived from IRPDs, including capitalised interest returned.

For the purposes of these statistics, IRPD revenue generally excludes:

  • consideration received for IRPDs of a non-revenue (capital) nature
  • foreign exchange gains returned for IRPDs.

Jurisdiction

The country or jurisdiction in which the non-resident counterparty to an IRPD is located.

For the purposes of the LFPA, jurisdiction is based on either:

  • the country of the permanent establishment of the IRP (if applicable), otherwise
  • the country of tax residence of the IRP.

LFPA

Local file – part A. An LFPA must be lodged by country-by-country (CBC) reporting entities with IRPDs for income years from 1 January 2016, unless exempted or excluded.

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