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IRPDs involving disposal or acquisition of tangible property of a non-revenue (capital) nature

Last updated 4 July 2023

 

Table 54: IRPDs involving disposal or acquisition of tangible property of a non-revenue (capital) nature

Code

Description of transaction category

RPRT

Real property

Any IRPDs in the nature of disposal or acquisition of real property of a non-revenue (capital) nature.

PLEQ

Plant or equipment

Any IRPDs in the nature of disposal or acquisition of plant or equipment of a non-revenue (capital) nature.

OTPRTY

Other tangible property

Any IRPDs in the nature of disposal or acquisition of tangible property of a non-revenue (capital) nature excluding the following property:

  • real property
  • plant or equipment.    

 

  1. Transaction Identifier

Show the Transaction ID for the transaction being reported.

(LCMSF31)

  1. Related Transaction Identifier(s)

Show all Transaction IDs that are related or directly connected to the transaction being reported.

(LCMSF206)

  1. What is the transaction category?

Select the transaction category for the IRPD transaction.

(LCMSF32)

  1. Is this transaction part of a RAS?

Always indicate False.

RAS reporting is not applicable to IRPD transactions of a non-revenue (capital) nature.

(LCMSF33)

  1. How many transactions are part of the RAS?

Not applicable.

(LCMSF35)

  1. Australian counterparty name

Show the full name of the Australian counterparty (which may be the reporting entity itself) to this transaction/RAS.

LCMSF207)

  1. ABN or TFN of the Australian counterparty to the transaction/RAS

Show the ABN or TFN or both of the Australian counterparty (which may be the reporting entity itself) to the transaction/RAS.

(LCMSF83 and LCMSF84)

  1. Name of the IRP non-resident counterparty to the transaction/RAS

Show the full name of the IRP non-resident counterparty to this transaction/RAS.

The full name to be shown is the complete name of the IRP non-resident counterparty entity. While this would be expected to usually correspond with the name of the relevant party in any associated written agreement documentation, the full correct name of the entity should be shown at Part A even if this is not exactly the same as the name used in any associated written agreement documentation.

(LCMSF37)

  1. Tax residency of the IRP non-resident counterparty to the transaction/RAS

Show the country code for the country of tax residence of the IRP non-resident counterparty to this transaction/RAS.

(LCMSF38)

  1. Was the transaction/RAS entered into by the non-resident counterparty in the course of its business operations carried on through a permanent establishment in a different country to its country of tax residence?

Indicate True if the transaction/RAS was entered into by the non-resident counterparty in the course of its business operations carried on through a PE in a different country to its country of tax residence.

Otherwise indicate False.

(LCMSF208)

  1. Country of permanent establishment of non-resident counterparty

This question applies only if you answered True to Question 10.

Show the country code of the PE through which the non-resident counterparty entered into the transaction/RAS. This code must not be the same as the code reported at Question 9 (LCMSF38) for the country of tax residence of the non-resident counterparty.

(LCMSF209)

  1. Amount of consideration paid (of a capital nature for income tax purposes) for the transaction

If an amount of a capital nature was paid by the reporting entity in connection with this transaction/RAS during the income year, show this amount based on its accounting records.

Show zero if no amount of a capital nature was paid by the reporting entity in connection with this transaction/RAS during the income year.

(LCMSF39)

  1. Amount of consideration received (of a capital nature for income tax purposes) for the transaction/RAS

If an amount of a capital nature was received by the reporting entity in connection with this transaction/RAS during the income year, show this amount based on its accounting records.

Show zero if no amount of a capital nature was received by the reporting entity in connection with this transaction/RAS during the income year.

(LCMSF40)

  1. Was non-monetary consideration provided (of a capital nature for income tax purposes) for the transaction/RAS?

Indicate True if non-monetary consideration of a capital nature was provided by the reporting entity in connection with this transaction/RAS during the income year.

Otherwise indicate False.

(LCMSF85)

  1. Was non-monetary consideration obtained (of a capital nature for income tax purposes) for the transaction/RAS?

Indicate True if non-monetary consideration of a capital nature was obtained by the reporting entity in connection with this transaction/RAS during the income year.

Otherwise indicate False.

(LCMSF86)

  1. Amount of expenditure (not of a capital nature for income tax purposes) for the transaction/RAS

Show the amount of expenditure not of a capital nature for income tax purposes in connection with this transaction/RAS during the income year based on the reporting entity’s accounting records.

Show zero if there was no amount of expenditure that is not of a capital nature in connection with this transaction/RAS during the income year.

(LCMSF41)

  1. Amount of revenue (not of a capital nature for income tax purposes) for the transaction/RAS

Show the amount of revenue not of a capital nature for income tax purposes in connection with this transaction/RAS during the income year based on the reporting entity’s accounting records.

Show zero if there was no amount of revenue that is not of a capital nature in connection with this transaction/RAS during the income year.

(LCMSF42)

  1. Average balance of debt interests issued (Inbound Borrowings)

Not applicable.

(LCMSF210)

  1. Capitalised interest deducted

Not applicable.

(LCMSF211)

  1. Average balance of debt interests held (Outbound Loans)

Not applicable.

(LCMSF212)

  1. Capitalised interest returned

Not applicable.

(LCMSF213)

  1. Book values

Not applicable. (LCMSF214)

  1. Was non-monetary consideration provided (not of a capital nature for income tax purposes) for the transaction/RAS?

Indicate True if non-monetary consideration not of a capital nature for income tax purposes was provided by the reporting entity in connection with this transaction/RAS during the income year.

Otherwise indicate False.

(LCMSF44)

  1. Was non-monetary consideration obtained (not of a capital nature for income tax purposes) for the transaction/RAS?

Indicate True if non-monetary consideration not of a capital nature for income tax purposes was obtained by the reporting entity in connection with this transaction/RAS during the income year.

Otherwise indicate False.

(LCMSF45)

  1. Is the debt interest (including borrowing/loan) interest-free?

Not applicable

(LCMSF237)

  1. Did you enter into a deferred foreign currency payment arrangement in relation to this transaction?

Not applicable for this transaction category.

(LCMSF215)

  1. Foreign Currency Reporting Type

Not applicable for this transaction category.

(LCMSF216)

  1. Foreign Currency Code

Not applicable for this transaction category.

(LCMSF217)

  1. Amount of foreign exchange losses deducted for the transaction/RAS

Show the amount of foreign exchange losses deducted for income tax purposes by the reporting entity in connection with this transaction/RAS under Division 775 of the ITAA 1997 or, if applicable, the taxation of financial arrangements (TOFA) provisions in Division 230 of the ITAA 1997 for the income year.

For more information about the circumstances in which foreign exchange gains are assessable and foreign exchange losses are deductible for Australian income tax purposes, refer to Appendix 6.

Show zero if there was no foreign exchange loss deducted for income tax purposes in connection with this transaction/RAS for the income year.

(LCMSF87)

  1. Foreign Currency Code

Show the Foreign Currency CodeExternal Link in relation to foreign exchange losses deducted for the transaction/RAS

(LCMSF219)

  1. Amount of foreign exchange gains returned for the transaction/RAS

Show the amount of foreign exchange gains assessable for income tax purposes in connection with this transaction/RAS under Division 775 of the ITAA 1997 or, if applicable, the TOFA provisions in Division 230 of the ITAA 1997 for the income year.

For more information about the circumstances in which foreign exchange gains are assessable and foreign exchange losses are deductible for Australian income tax purposes, refer to Appendix 6.

Show zero if there was no foreign exchange gain assessable for income tax purposes in connection with this transaction/RAS.

(LCMSF43)

  1. Foreign Currency Code

Show the Foreign Currency CodeExternal Link in relation to assessable foreign exchange gains for the transaction/RAS

(LCMSF221)

  1. What transfer pricing/capital asset pricing methodology has been applied to this transaction/RAS?

Select the code UNKT (Unknown TP Method) if the reporting entity does not know which transfer pricing methodology has been applied to this transaction/RAS.

Select UNKC (Unknown CAP Method) if the reporting entity does not know which capital asset pricing methodology has been applied to this transaction/RAS.

(LCMSF46)

  1. What level of transfer pricing documentation has been prepared for this transaction/RAS?

The level of transfer pricing documentation refers to the aggregate dollar amount of this transaction/RAS for which the reporting entity has prepared relevant transfer pricing documentation, expressed as a percentage of total dollar value of this transaction/RAS.

1 = 0%

2 = 1% to less than 25%

3 = 25% to less than 50%

4 = 50% to less than 75%

5 = 75% to less than 100%

6 = 100%

This transaction/RAS will not meet the conditions for any of the simplified record keeping (STPRK) options in PCG 2017/2 Simplified Transfer Pricing Record Keeping Options since it is not a services or loan arrangement and it involves an IRPD of a capital nature.

(LCMSF47)

  1. If the reporting entity is a bank and this transaction is in a RAS, has the special short-term tenor rule for ordinary borrowings and ordinary loans been applied to this RAS?

Always indicate False if the transaction category is not ordinary borrowings or ordinary loans.

(LCMSF88)

  1. If the reporting entity is a bank and this transaction is in a RAS, has the special short-term tenor rule for short term derivatives been applied to this RAS?

Always indicate False if the transaction category is not derivatives.

(LCMSF128)

  1. If the reporting entity is a bank and this transaction is in a RAS, has the special short-term tenor rule for FX derivatives been applied to this RAS?

Always indicate False if the transaction category is not derivatives.

(LCMSF129)

  1. If the reporting entity is an OBU, is this transaction/RAS an OB activity?

Always indicate False since acquisition or disposal of tangible property of a non-revenue (capital) nature is not an OB activity under section 121D of the ITAA 1936.

(LCMSF63)

  1. Is this transaction/RAS covered by a category on the exclusions list?

Indicate False, since none of the categories on the exclusions list can apply to a disposal or acquisition or disposal of tangible property of a non-revenue (capital) nature.

(LCMSF48)

  1. What category of the exclusions list applies to this transaction/RAS?

Not applicable.

(LCMSF49)

  1. Transaction Comments

Provide any relevant comments in respect of the transaction/RAS.

QC72969