Other revenue IRPDs

Last updated 4 July 2023

Table 17: Other revenue IRPDs
Code	Description of transaction category
CCA	Cost contribution arrangement Any IRPDs in the nature of a cost contribution arrangement for developing, producing or obtaining assets or rights and defining the interests of each participant in those assets or rights. This excludes IRPD arrangements solely involving provision or obtaining of services, and where the parties do not all obtain an interest in property or other rights or benefits under the arrangement. Such arrangements are treated as comprising the relevant IRPD services transactions for local file reporting purposes.
ORIRPD	Other revenue (non-financial dealing) IRPDs Any IRPDs of a revenue nature excluding any of the following transaction categories: Tangible property of a revenue nature Rights to use IP Other rights to use, supply or receive where consideration is royalty under section 6(1) Licence fees Rent of real property Hire or lease of plant or equipment Lease or hire of other property or rights Share based employment remuneration Cost contribution arrangement IRPD service arrangements IRPD Debt Interests (including ordinary loans and borrowings) IRPD Derivative transactions 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. This transaction category does not include dividends or other distributions of profit on ordinary shares or equity interests of a non-revenue nature. For the avoidance of doubt, ordinary shares or equity interests do not include hybrid equity or other arrangements where the characterisation between debt and equity is different under Division 974 of the Income Tax Assessment Act 1997 (ITAA 1997) and your treatment for accounting purposes. These arrangements should be reported as Other Financial Dealings unless another more specific transaction category applies.

Any amounts provided at any of the below questions should be reported in whole dollars and cents.

Transaction Identifier

Show the Transaction ID for the transaction being reported.

(LCMSF31)

Related Transaction Identifier(s)

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

(LCMSF206)

What is the transaction category?

Select the transaction category for the IRPD transaction.

(LCMSF32)

Is this transaction part of a RAS?

If this transaction is covered by an IRPD agreement in a RAS, indicate True.

Otherwise indicate False. (LCMSF33)

How many transactions are part of the RAS?

If the transaction is part of a RAS, indicate the applicable range for the number of the transactions in the same RAS that were current during the income year:

Low (2–5)
Moderate (6–50)
High (51 or more)

(LCMSF35)

Australian counterparty name

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

(LCMSF207)

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)

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)

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)

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)

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)

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

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 the reporting entity’s 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)

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 the reporting entity's 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)

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)

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)

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 not of a capital nature in connection with this transaction/RAS during the income year.

(LCMSF41)

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 not of a capital nature in connection with this transaction/RAS during the income year.

(LCMSF42)

Average balance of debt interests issued (Inbound Borrowings)

Not applicable.

(LCMSF210)

Capitalised interested deducted

Not applicable.

(LCMSF211)

Average balance of debt interests held (Outbound Loans)

Not applicable.

(LCMSF212)

Capitalised interest returned

Not applicable.

(LCMSF213)

Book values

Not applicable.

(LCMSF214)

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)

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)

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

Not applicable

(LCMSF237)

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

Not applicable for this transaction category.

(LCMSF215)

Foreign Currency Reporting type

Not applicable.

(LCMSF216)

Foreign Currency Code

Not applicable.

(LCMSF217)

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)

Foreign Currency Code

This question applies only if you answered False to Question 26.

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

(LCMSF219)

Amount of foreign exchange gains returned for the transaction/RAS

This question applies only if you answered False to Question 26.

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 for the income year.

(LCMSF43)

Foreign Currency Code

This question applies only if you answered False to Question 26.

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

(LCMSF221)

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)

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%

If this transaction/RAS meets the conditions for one of the following Simplified Transfer Pricing Record Keeping (STPRK) options, outlined in PCG 2017/2 Simplified Transfer Pricing Record Keeping Options, show the codes for the STPRK option applied to the transaction/RAS:

7 = STPRK (Materiality)

8 = STPRK (Small Taxpayers)

9 = STPRK (Distributors)

(LCMSF47)

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)

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)

If the reporting entity is a bank and this transaction is in a RAS, has the special rule for FX derivatives been applied to this RAS?

Always indicate False if the transaction category is not derivatives.

(LCMSF129)

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

If the reporting entity is an OBU and this transaction/RAS is an OB activity under sections 121D and 121EAA of the ITAA 1936, indicate True.

Otherwise indicate False.

(LCMSF63)

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

Indicate True if this transaction/RAS is covered by one of the following categories on the exclusions list.

Otherwise indicate False.

(LCMSF48)

What category of the Exclusions List applies to this transaction/RAS?

If you indicated True to Question 39, select the category on the exclusions list which applies to this transaction/RAS.

(LCMSF49)

Transaction Comments

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

You must provide a short description if the kind of transaction being reported is ORIRPD (Other revenue (non-financial dealing) IRPDs).

(LCMSF222)

Reporting example: Other revenue IRPDs

Example 10: Cost contribution arrangement with Bermudan and US IRPs

Aus Co is a company that is resident in Australia for tax purposes.

Aus Co has an income tax year ending 30 June.

Aus Co’s functional currency for Australian tax purposes is Australian dollars.

Prior to the income year, Aus Co entered into a cost contribution agreement with an IRP resident for tax purposes in Bermuda (Bermuda Co) and an IRP resident for tax purposes in the US (US Co). Under the terms of the cost contribution agreement:

Bermuda Co and US Co agreed to pay a specified portion of the costs incurred by Aus Co in relation to developing new plant and equipment in connection with its Australian mining operations
US Co agreed to make certain premises available to Aus Co for the development activities
Bermuda Co agreed to contribute use of certain patents and registered designs for the development activities
Bermuda Co and US Co would have title to a specified extent to any patents or designs created by the development activities conducted by Aus Co.

During the income year Aus Co has patented inventions resulting from Aus Co’s development activities under the cost contribution arrangement. The patents for these inventions were issued in the name of Bermuda Co.

The amount of costs incurred by Aus Co in performing the development activities covered by the cost contribution arrangement that were reimbursed by Bermuda Co and US Co under the arrangement is shown in the table below.

Table 18: Costs incurred by Aus Co

Table 18: Costs incurred by Aus Co
Nature of costs incurred by Aus Co	Amount of costs incurred by Aus Co	Amount reimbursed by Bermuda Co	Amount reimbursed by US Co
Purchase of plant and equipment	$10m	$1m	$2m
Salary and wages	$5m	$1m	$1m

All costs that were incurred or reimbursed by Aus Co under the cost contribution arrangement were incurred or reimbursed in Australian dollars.

Aus Co has not yet earned any revenue as a result of the development activities under the cost contribution arrangement, except for payments made by Bermuda Co and US Co as reimbursement of the salary and wage costs incurred by Aus Co under the cost contribution arrangement.

The only monetary consideration of a capital nature obtained by Aus Co was the reimbursement by Bermuda Co and US Co of costs for the plant and equipment.

Aus Co did provide non-monetary consideration of a capital nature to Bermuda Co, being title to the patents for the inventions resulting from Aus Co’s development activities under the cost contribution arrangement.

Aus Co did obtain non-monetary consideration not of a capital nature for income tax purposes from Bermuda Co in relation to the cost contribution arrangement, being the right to use certain patents and registered designs made available by Bermuda Co.

Aus Co did obtain non-monetary consideration not of a capital nature for income tax purposes from US Co in relation to the cost contribution arrangement, being the right to use or access certain premises made available by US Co.

Aus Co has applied the transfer pricing methodology ‘Cost contribution arrangement’ to all payments and benefits obtained or made by Aus Co under the cost contribution arrangement.

Aus Co has prepared relevant contemporaneous transfer pricing documentation for 100% of the cost contribution arrangement.

Neither Bermuda Co nor US Co carry on their business operations through a permanent establishment.

Aus Co completes the questions for the IRP transactions/RAS in this example based on its accounting records as shown in the following tables. At this stage, the form can only support one non-resident IRP counterparty.

Table 19: Completed entry for Example 10 – Cost contribution arrangement with Bermuda Co

Table 19: Completed entry for Example 10 – Cost contribution arrangement with Bermuda Co
Question no.	Question label	Response
1	Transaction Identifier	[Transaction ID for CCA transaction in Table 20]
2	Related Transaction Identifier	[Transaction IDs]
3	Transaction category	CCA
4	Is this transaction part of a RAS?	False
5	How many transactions are part of the RAS?	Na
6	Australian counterparty name	[Australian counterparty name]
7	ABN or TFN of the Australian counterparty to the transaction/RAS	[ABN or TFN]
8	Name of the IRP non-resident counterparty to the transaction/RAS	Bermuda Co
9	Tax residence of the IRP non-resident counterparty to the transaction/RAS	BM
10	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?	False
11	Country of permanent establishment counterparty	Na
12	Amount of consideration paid (of a capital nature for income tax purposes) for the transaction/RAS	0
13	Amount of consideration received (of a capital nature for income tax purposes) for the transaction/RAS	1000000
14	Was non-monetary consideration provided (of a capital nature for income tax purposes) for the transaction/RAS?	True
15	Was non-monetary consideration obtained (of a capital nature for income tax purposes) for the transaction/RAS?	False
16	Amount of expenditure (not of a capital nature for income tax purposes) for the transaction/RAS	0
17	Amount of revenue (not of a capital nature for income tax purposes) for the transaction/RAS	1000000
18	Average balance of debt interests issued (Inbound Borrowings)	Na
19	Capitalised interest deducted	Na
20	Average balance of debt interests held (Outbound Loans)	Na
21	Capitalised interest returned	Na
22	Book values	Na
23	Was non-monetary consideration provided (not of a capital nature for income tax purposes) for the transaction/RAS?	False
24	Was non-monetary consideration obtained (not of a capital nature for income tax purposes) for the transaction/RAS?	True
25	Is the debt interest (including borrowing/loan) interest-free?	Na
26	Did you enter into a deferred foreign currency payment arrangement in relation to this transaction	Na
27	Foreign Currency Reporting Type	Na
28	Foreign Currency Code	Na
29	Amount of foreign exchange losses deducted for the transaction/RAS	0
30	Foreign Currency Code	Na
31	Amount of foreign exchange gains returned for the transaction/RAS	0
32	Foreign Currency Code	Na
33	What transfer pricing/capital asset pricing methodology has been applied to the transaction/RAS?	CCA
34	What level of transfer pricing documentation has been prepared for this transaction/RAS?	6
35	If the reporting entity is a bank and transaction is in a RAS, has the special short term tenor rule for ordinary borrowings and ordinary loans been applied to this RAS?	False
36	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?	False
37	If the reporting entity is a bank and this transaction is in a RAS, has the special rule for FX derivatives been applied to this RAS?	False
38	If the reporting entity is an OBU, is this transaction/RAS an OB activity?	False
39	Is this transaction/RAS covered by a category on the Exclusions List?	False
40	What category of the Exclusions List applies to this transaction/RAS?	Na
41	Transaction Comments	[Comments]

Table 20: Completed entry for Example 10 – Cost contribution arrangement with US Co

Table 20: Completed entry for Example 10 – Cost contribution arrangement with US Co
Question no.	Question label	Response
1	Transaction Identifier	[Transaction ID]
2	Related Transaction Identifier(s)	[Transaction IDs for CCA transaction in Table 19]
3	Transaction category	CCA
4	Is this transaction part of a RAS?	False
5	How many transactions are part of the RAS?	Na
6	Australian counterparty name	[Australian counterparty name]
7	ABN or TFN of the Australian counterparty to the transaction/RAS	[ABN or TFN]
8	Name of the IRP non-resident counterparty to the transaction/RAS	US Co
9	Tax residence of the IRP non-resident counterparty to the transaction/RAS	US
10	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?	False
11	Country of permanent establishment counterparty	Na
12	Amount of consideration paid (of a capital nature for income tax purposes) for the transaction/RAS	0
13	Amount of consideration received (of a capital nature for income tax purposes) for the transaction/RAS	2000000
14	Was non-monetary consideration provided (of a capital nature for income tax purposes) for the transaction/RAS?	False
15	Was non-monetary consideration obtained (of a capital nature for income tax purposes) for the transaction/RAS?	False
16	Amount of expenditure (not of a capital nature for income tax purposes) for the transaction/RAS	0
17	Amount of revenue (not of a capital nature for income tax purposes) for the transaction/RAS	1000000
18	Average balance of debt interests issued (Inbound Borrowings)	Na
19	Capitalised interest deducted	Na
20	Average balance of debt interests held (Outbound Loans)	Na
21	Capitalised interest returned	Na
22	Book values	Na
23	Was non-monetary consideration provided (not of a capital nature for income tax purposes) for the transaction/RAS?	False
24	Was non-monetary consideration obtained (not of a capital nature for income tax purposes) for the transaction/RAS?	True
25	Is the debt interest (including borrowing/loan) interest-free?	Na
26	Did you enter into a deferred foreign currency payment arrangement in relation to this transaction	Na
27	Foreign Currency Reporting Type	Na
28	Foreign Currency Code	Na
29	Amount of foreign exchange losses deducted for the transaction/RAS	0
30	Foreign Currency Code	Na
31	Amount of foreign exchange gains returned for the transaction/RAS	0
32	Foreign Currency Code	Na
33	What transfer pricing/capital asset pricing methodology has been applied to the transaction/RAS?	CCA
34	What level of transfer pricing documentation has been prepared for this transaction/RAS?	6
35	If the reporting entity is a bank and transaction is in a RAS, has the special short-term tenor rule for ordinary borrowings and ordinary loans been applied to this RAS?	False
36	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?	False
37	If the reporting entity is a bank and this transaction is in a RAS, has the special rule for FX derivatives been applied to this RAS?	False
38	If the reporting entity is an OBU, is this transaction/RAS an OB activity?	False
39	Is this transaction/RAS covered by a category on the Exclusions List?	False
40	What category of the Exclusions List applies to this transaction/RAS?	Na
41	Transaction Comments	[Comments]

End of example

QC72969

Other revenue IRPDs

Reporting example: Other revenue IRPDs

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