Local file changes from 1 January 2025

May to June 2024

V 4.0 draft specifications to digital service providers (including external vendor testing environment code deployment).

July to September 2024

• Industry liaison
• Advance instructions provided to stakeholders.

July to December 2024

Building and testing by digital service providers.

Provide a description of your business and strategy. 

You should:

• identify all of your main business lines and functions
• describe the strategies deployed in each business line or function
• describe the extent each business line or function overlaps or complements each other.

When describing your business and the strategies deployed for each business line or function, you should consider consistency with the other disclosures such as those made in the director's report section of your annual report (if applicable) or those made in other management or reporting documents.

Provide a list of key competitors of the reporting entity.

The list of key competitors should be provided for all of your main business lines and functions identified in your disclosures relating to your business and strategy.

• Number of main business lines or functions.
• Description of each main business line or function.
• For each above business line/function
  • business strategies employed
  • extent of overlap with other main business lines/functions
  • key competitors.

Provide a description and copy of your organisational structure, including a description of the individuals to whom local management reports and the countries in which such individuals maintain their principal offices.

You should include:

• the job title and responsibilities of the most senior Australian based individuals to whom the local staff reported for each separately reporting local business line or function at the end of the income year
• in the case of foreign owned entities and operations, and any other scenario in which there is formal or effective overseas reporting 
  • the job title and responsibilities of the overseas based individuals to which the identified most senior Australian based individuals effectively report at the end of the income year
  • the countries in which such overseas individuals maintain their principal offices 
• the name of the entity which employs the identified overseas based individuals
• information about multiple reporting lines where the identified most senior Australian based individuals formally or effectively report to more than one overseas based individuals.

If there was any change during the income year in the most senior Australian based individuals to whom the local staff reported for each separately reporting local business line or function, or in the individuals or countries to which the most senior Australian based individuals reported, provide:

• the date on which the change occurred
• the information requested above for the reporting arrangements just prior to the change.

• Whether you had any personnel employed in your operations effectively reporting to overseas personnel (Yes/No).
• If No, attach a diagram of your organisational structure and move to next reporting section.
• If Yes, provide:
  • name, job title and employing entity details (including TFN or ABN) for your reporting personnel
  • number of different individual overseas personnel to whom your personnel reported
  • name, job title, residency, principal office location and employing entity details for overseas personnel
  • description of function/activities for which reporting occurred
  • if this reporting commenced or ceased during the income year, commencement/cessation dates
  • attach a diagram of your organisational structure.

Provide a description of any business restructures affecting your business in the current or previous income year and an explanation of its significance.

You should describe any significant business restructures that have occurred during the reporting period or previous income year, and an explanation of its significance, including:

• significant changes in your ownership, equity or related party debt funding
• significant disposal or acquisition of your assets, including interests in foreign entities
• commencement or cessation of significant operations including operations of your controlled foreign companies or entities (CFCs) and operations you carry on at or through an overseas permanent establishment
• any resulting cross border tax hybrid arrangements.

This covers any significant changes of, and disposals or acquisitions by, any member of your Australian consolidated group or MEC group, and any of your CFCs.

In determining whether a change, disposal or acquisition is significant, take into account the anticipated impact on your Australian tax liabilities for the income period and following income years, including any anticipated impact on Australian withholding tax liabilities.

The description should include:

• the commercial context and explanation for the changes, or disposals or acquisitions
• a description of transactions or dealings connected with the changes, disposals or acquisitions.

(Examples are included which illustrate the required level of reporting for each connected step of the restructure)

• Whether you had any:
  • restructure (including any change in related party financing), or
  • any new arrangement involving transfer, licence or creation of intangibles (intangibles arrangement)

(Yes/No)

• If No, reporting section completed.
• If Yes, provide:
  • code (high level type) and description for restructure/arrangement
  • if intangibles arrangement, code for types of intangibles involved
  • anticipated Australian tax impact (including high level code) and global tax impact of restructure/arrangement
  • commercial context and impact of restructure/arrangement
  • code (based on IDS Q17 Appendix 11 codes) for total capital value of restructure/arrangement
  • number of steps in restructure/arrangement
  • for each step:
    • date
    • code (high level type) and description
    • number of parties to the step
    • name of parties
    • if the party is an international related party or Australian constituent entity, residency/branch details if applicable
    • if the party is an Australian constituent entity, TFN or ABN
    • details of any connected change in transfer pricing functional characterisation
  • if there was a step plan, attach the step plan.

Provide a description of any transfers of intangibles in the current or previous income year and an explanation of its significance.

You should describe any transfer of intangibles including any connected arrangements, such as related party licensing or service agreements, that occurred in the current or previous income year.

The term intangible includes property, assets or rights that are not physical or financial assets, which are capable of being owned or controlled for use in commercial activities. Examples of intangibles include intellectual property, goodwill, rights under service or distribution agreements, know-how and the right to access secret information or processes.

The description should include:

• the commercial context and explanation for the transfer of intangibles
• a description of transactions or dealings connected with the transfer of intangibles.

This covers any transfer of intangibles by any member of your Australian consolidated group or MEC group, or by any of your CFCs.

(Examples are included which illustrate the required level of reporting for each connected step of the intangibles arrangement)

Covered by MST fields for Restructures (above).