- How these instructions apply
- IRP and IRPD
- Local file – short form
- Local file – Part A
- IRPDs in tangible property of a revenue nature
- IRPD service arrangements
- IRPD use rights
- IRPD share-based employment remuneration
- Other revenue IRPDs
- IRPD derivative transactions
- IRPD debt interests (including ordinary loans and borrowings)
- IRPD debt factoring or debt securitisation
- Other kinds of IRPDs of a financial nature
- IRPDs involving disposal or acquisition of tangible property of a non-revenue (capital) nature
- IRPDs involving disposal or acquisition of intangible property or rights of a non-revenue (capital) nature
- IRPD foreign currency deferred payment arrangements
- Local file – Part B
While these instructions are not a guide to income tax law, you can use them to help you complete your local file when meeting this part of your country-by-country (CBC) reporting obligations.
These instructions apply to the local file for 2023. This relates to reporting periods starting from 1 January 2022.
The local file must be electronically lodged in the approved form (an XML file –generated in accordance with an ATO developed XML schema). The local file is part of a combined form, which also contains the master file. The local file may be lodged separately or together with the master file.
The local file can only be lodged electronically, through one of the following:
- Online services for business using file transfer
- Online services for agents using file transfer
- Standard Business ReportingExternal Link (SBR) using SBR-enabled software.
Lodgments via email or paper are not accepted.
The information requirements (high level design) and associated specifications (detailed design) for the local file are contained in the Local file/master file 2023. Reference to specific form elements is made via element IDs in the form of 'LCMSFXXX'.
The local file collects information and relevant documentation for international related party dealings (IRPDs). The local file is comprised of three parts:
Specific features include:
- Aggregating values shown in Part A for transactions covered by the same relevant agreement series RAS.
- Not needing to provide written agreements in Part B if the IRPD transaction/RAS is covered by one of the eight categories on the exclusions list.
Where a reporting entity enters into a transaction with multiple IRP non-resident counterparties, they must complete Part A showing transactions for each IRP non-resident counterparty to the transaction.
If you have feedback or questions regarding these instructions, contact us at CBCReporting@ato.gov.au