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Local file – Part B

How to complete Part B of the local file.

Published 7 August 2026

When Part B does not need to be completed

Part B does not need to be completed for an IRP transaction/RAS shown at Part A if the IRP transaction/RAS is covered by a category on the exclusions list. Further specific guidance on providing IRP agreements as part of Part B of the local file is also available in Appendix 8.

Methods available to complete Part B

  1. Transaction focused reporting method: Requires one Part B record for each Part A transaction ID, with agreement information reported for each record.
  2. Streamlined LFPB reporting method (optional): Requires a single Part B record for all Part A transaction records that share the same Part B information, reducing duplication where applicable. (Where Part A transaction records don't share the same Part B information record, a one-to-one (transaction-focused) approach will still be required.)

Instructions to complete Part B

The following instructions apply if the IRP transaction/RAS shown at Part A is not covered by a category on the exclusions list.

  1. Transaction Identifier

Show the transaction identifier used in Part A for the IRP transaction/RAS.

(LCMSF50)

  1. Which transfer pricing/capital asset pricing methodology has the IRP relied upon for this transaction/RAS?

Show the code for the transfer pricing methodology/capital asset pricing methodology the IRP has relied upon for this IRP transaction/RAS.

(LCMSF51)

  1. Is the reporting entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction/RAS?

This question applies if the reporting entity indicates at Question 2 that the methodology is unknown.

If the reporting entity is not able to obtain information from the IRP of the relevant methodology the IRP relied upon for this transaction/RAS, indicate True.

Otherwise indicate False.

(LCMSF130)

  1. Is there written agreement or other relevant documentation evidencing the terms of the agreement covering this transaction/RAS (as reported in Part A)?

If there is written agreement documentation covering this transaction/RAS (as reported in Part A), indicate True.

If there is no written agreement documentation evidencing the terms of the agreement covering this transaction/RAS (as reported in Part A), indicate False.

In the case of a foreign currency deferred payment arrangement transaction, Question 4 is asking whether there is a separate written agreement for the financing arrangement which results from deferral of payment of an amount of foreign currency owing under another underlying IRP transaction. Question 4 is not asking whether there is a written agreement for the underlying non-financing IRP transaction itself.

For example, if there is a FCDPTTS transaction because there was a deferred foreign currency payment arrangement for the sale price due and owing under an IRP commodity sale transaction, Question 4 is not asking if there is a written agreement for the IRP commodity sale transaction. It is instead asking if there is a separate written agreement for the financing arrangement which results from not satisfying the payment obligation.

(LCMSF52)

  1. Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction/RAS (as reported at Part A)?

This question applies if you have answered True to Question 4

If the reporting entity is unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the IRP transaction/RAS (as reported at Part A), indicate True.

Otherwise indicate False.

(LCMSF64)

  1. Other Transaction IDs covered by the agreement

Provide all the other transaction identifiers that are covered by the agreement. This must not include the transaction identifier provided at Question 1.

(LCMSF224)

  1. Has the written agreement documentation been previously provided to the ATO?

This question applies if you have answered True to Question 4 and False to Question 5.

Indicate True if the written agreement documentation for this IRP transaction/RAS has been previously provided to the ATO by the reporting entity.

Don't indicate True if the written agreement documentation for this IRP transaction/RAS was not previously provided by the reporting entity lodging this Local File statement.

Otherwise indicate False.

(LCMSF53)

  1. Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

This question applies if you have answered True to Question 7.

Indicate True if the written agreement documentation was provided as part of a local file lodged for a previous reporting period.

Otherwise indicate False.

(LCMSF239)

  1. Title of the agreement(s) previously provided to the ATO

This question applies only if you answered True to Question 7.

Show either:

  • the title of each agreement previously provided to the ATO
  • the filename of each agreement that was attached in Part B as part of a local file lodgment for a previous reporting period.

Where more than one agreement was previously provided for a transaction, show each title or filename separately. Each filename must not exceed 255 characters or contain special characters. Where an agreement was not previously provided electronically, adopt a 'best efforts' approach if the title of an agreement exceeds 255 characters or contains special characters.

(LCMSF54)

  1. What is the year in which the agreement(s) was previously provided to the ATO?

This question applies only if you answered True to Question 7

Show the year in which the written agreement documentation for this IRP transaction/RAS was provided to the ATO.

You show the year in which you provided the agreement(s), rather than showing the income year for which the agreement(s) were provided. For example, if you provided agreement(s) in your 2020 local file Part B for your 2020 income year, and your 2020 local file Part B was lodged in 2021, you show 2021, not 2020.

(LCMSF90)

  1. Please confirm that you have attached the agreements for this transaction/RAS

This question applies only if you answered False to Question 7.

If the written agreement documentation for this IRP transaction/RAS has been attached, indicate True.

If you have indicated False at Question 4 because there is no written agreement documentation for this IRP transaction/RAS, if you want to you can attach other records or documents for this IRP transaction/RAS. For more about this refer to paragraphs 15 and 16 of Appendix 8.

(LCMSF89)

  1. Filename(s) of IRP Agreement(s)

This question applies only if you answered True to Question 11.

Provide the filename(s) including the filename extension of the attachments. For example, 'IRP Agreement.pdf'.

(LCMSF225)

  1. Since providing the written agreement to the ATO, has the agreement been amended?

This question applies only if you answered True to Question 7.

If the agreement has been amended since the written agreement documentation was previously provided to the ATO, indicate True.

Otherwise indicate False.

(LCMSF91)

  1. Have the amended agreements or agreements incorporating the amendments been previously provided to the ATO?

This question applies only if you answered True to Question 13.

Indicate True if the amendment agreements or the amended agreement incorporating all the amendments have been provided to the ATO.

Don't indicate True if the amended agreements or the amended agreement incorporating all the amendments for this IRP transaction/RAS was not previously provided by the reporting entity lodging this Local File statement.

Otherwise indicate False.

(LCMSF92)

  1. Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

This question applies only if you answered True to Question 14.

Indicate True if the amended agreements or the amended agreement incorporating all the amendments were provided as part of a local file lodged for a previous reporting period.

Otherwise indicate False.

(LCMSF240)

  1. What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

This question applies only if you answered True to Question 14.

Show either:

  • the title of each amendment agreement or agreement incorporating all the amendments previously provided to the ATO, or
  • the filename of each amendment agreement or agreement incorporating all the amendments that was attached in Part B as part of a local file lodgment for a previous reporting period.

Where more than one amendment agreement was previously provided for a transaction, show each title or filename separately. Each filename must not exceed 255 characters or contain special characters. Where an amendment agreement or an agreement incorporating all the amendments was not previously provided electronically, adopt a 'best efforts' approach if the title of an agreement exceeds 255 characters or contains special characters.

(LCMSF132)

  1. What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

This question applies only if you answered True to Question 14.

Show the year in which the amendment agreements or the amended agreement incorporating all the amendments documentation for this IRP transaction/RAS was provided to the ATO.

You show the year in which you provided the amendment agreement(s), rather than showing the income year for which the amendment agreement(s) were provided. For example, if you provided the amendment agreement(s) in your 2020 local file Part B for your 2020 income year, and your 2020 local file Part B was lodged in 2021, you show 2021, not 2020.

(LCMSF133)

  1. Please confirm that you have attached the amendments for previously provided agreements for this transaction/RAS

This question applies only if you answered False to Question 14.

Confirm that you have attached the amendment agreements or the amended agreement incorporating all the amendments for previously provided agreements for this transaction/RAS, by indicating True.

(LCMSF131)

  1. Filename(s) of the amended agreement(s)

This question applies only if you answered True to Question 18.

Provide the filename(s) including the filename extension of the attachments. For example, 'IRP Amended Agreement.pdf'.

(LCMSF226)

  1. Are there APAs or rulings provided by other jurisdictions for this transaction/RAS?

If there are any APAs or rulings provided by an overseas jurisdiction for this IRP transaction/RAS, indicate True.

Otherwise indicate False.

(LCMSF106)

  1. Which other Transaction IDs does that APA/ruling cover?

This question applies only if you answered True to Question 20.

Provide all the other transaction identifiers that are covered by the APA or ruling. This must not include the transaction identifier provided at Question 1.

(LCMSF228)

  1. Has the reporting entity previously provided these APAs/rulings to the ATO?

This question applies only if you answered True to Question 20.

If the reporting entity has previously provided these APAs/rulings to the ATO, indicate True.

Do not indicate True if the APAs/rulings for this IRP transaction/RAS were not previously provided by the reporting entity lodging this Local File statement.

Otherwise indicate False.

(LCMSF134)

  1. Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

This question applies only if you answered True to Question 22.

If the reporting entity has previously provided these APAs/rulings to the ATO as part of a local file lodged for a previous reporting period, indicate True.

Otherwise indicate False.

(LCMSF241)

  1. What is the filename of the APAs/Rulings previously provided to the ATO?

This question applies only if you answered True to Question 22.

Provide the filename(s) including the filename extension of the attachments. For example, 'Transaction 1 APA.pdf'.

(LCMSF238)

  1. What is the year in which the reporting entity previously provided these APAs/rulings?

This question applies only if you answered True to Question 22.

Show the year in which the APAs or rulings for this IRP transaction/RAS were previously provided to the ATO.

You show the year in which you provided the APAs or rulings, rather than showing the income year for which the APAs or rulings were provided. For example, if you provided the APAs or rulings in your 2020 local file Part B for your 2020 income year, and your 2020 local file Part B was lodged in 2021, you show 2021, not 2020.

(LCMSF136)

  1. Please confirm that you have attached the relevant APAs/rulings for this transaction/RAS

This question applies only if you answered False to Question 22.

Confirm that you have attached the relevant APAs/rulings for this IRP transaction/RAS, by indicating True.

(LCMSF135)

  1. Filename(s) of the APAs/Rulings

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

Provide the filename(s) including the filename extension of the attachments. For example, 'Transaction 1 APA.pdf'.

(LCMSF229)

New streamlined LFPB reporting method (optional)

An optional streamlined reporting method is now available to address duplicated Part B information provided for more than one transaction reported in Part A. For further information, see methods available to complete Part B which includes worked examples showing when the new streamlined method can be used, and how it differs from the original method of reporting (transaction focused).

Eligibility for streamlined LFPB reporting method

We have introduced an optional streamlined reporting method for Part B. This method allows agreements and other relevant documentation for multiple Part A IRP transactions/RAS to be reported in one Part B record where:

  • all relevant transactions are reported at either Question 1 (‘Transaction Identifier’) or Question 6 (‘Other Transaction IDs covered by the agreement’), and
  • all transaction and agreement information in Part B (including where applicable, APAs/rulings information) is identical. Part B information may be identical if no written agreement documentation exists (see Example 2).

Examples

  • Example 1: Written agreement covers multiple transactions and all Part B transaction and agreement information identical
  • Example 2: No written agreements or other relevant documentation covering the IRP transactions/RAS, all Part B transaction information identical.
  • Example 3: Written agreement covers multiple transactions but Part B information is NOT identical as different transfer pricing methodologies apply to each transaction.

Example 1: Written agreement covers multiple transactions and all Part B transaction and agreement information identical

  • Aus Co has a single written agreement covering 3 separate IRP transactions shown at Part A with unique transaction IDs. The transfer pricing (TP) methodology and agreement details are identical across these transactions and there are no APAs or rulings covering these transactions.

Transaction focused reporting method (multiple Part B records)

If Aus Co chooses to use the transaction focused reporting method, one Part B record per transaction ID is required to be reported, with identical agreement information repeated for each record.

Using the transaction focused reporting method, Aus Co completes the questions for Part B as shown in the following tables.

Table 1: Record 1 for Local File Part B using transaction focused reporting method

Question number

Question label

Response

1.

Transaction identifier

1

2.

Which transfer pricing/capital asset pricing methodology has the IRP relied on this transaction/RAS?

TNMM

3.

Is the reporting entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction/RAS?

False

4.

Is there a written agreement or other relevant document evidencing the terms of the agreement covering this transaction/RAS?

True

5.

Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction/RAS (as reported at Part A)?

False

6.

Other Transaction IDs covered by the agreement

2, 3

7.

Has the written agreement documentation been previously provided to the ATO?

False

8.

Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

n/a

9.

Title of the agreement(s) previously provided to the ATO

n/a

10.

What is the year in which the agreement(s) was previously provided to the ATO?

n/a

11

Please confirm that you have attached the agreements for this transaction/RAS

True

12

Filename(s) of IRP Agreement(s)

LFPBI_Intercompany_Supply_Agreement.pdf

13

Since providing the written agreement to the ATO, has the agreement been amended?

na

14

Have the amended agreements or agreements incorporating the amendments been previously provided to the ATO?

na

15

Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

16

What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

na

17

What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

na

18

Please confirm that you have attached the amendments for previously provided agreements for this transaction/RAS

na

19

Filename(s) of the amended agreement(s)

na

20

Are there APAs or rulings provided by other jurisdictions for this transaction/RAS?

False

21

Which other Transaction IDs does that APA/ruling cover?

na

22

Has the reporting entity previously provided these APAs/rulings to the ATO?

na

23

Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

24

What is the filename of the APAs/Rulings previously provided to the ATO?

na

25

What is the year in which the reporting entity previously provided these APAs/rulings?

na

26

Please confirm that you have attached the relevant APAs/rulings for this transaction/RAS

na

27

Filename(s) of the APAs/Rulings

na

Table 2: Record 2 for Local File Part B using transaction focused reporting method

Question number

Question label

Response

1.

Transaction identifier

2

2.

Which transfer pricing/capital asset pricing methodology has the IRP relied on this transaction/RAS?

TNMM

3.

Is the reporting entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction/RAS?

False

4.

Is there a written agreement or other relevant document evidencing the terms of the agreement covering this transaction/RAS?

True

5.

Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction/RAS (as reported at Part A)?

False

6.

Other Transaction IDs covered by the agreement

1, 3

7.

Has the written agreement documentation been previously provided to the ATO?

False

8.

Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

n/a

9.

Title of the agreement(s) previously provided to the ATO

n/a

10.

What is the year in which the agreement(s) was previously provided to the ATO?

n/a

11

Please confirm that you have attached the agreements for this transaction/RAS

True

12

Filename(s) of IRP Agreement(s)

LFPBI_Intercompany_Supply_Agreement.pdf

13

Since providing the written agreement to the ATO, has the agreement been amended?

na

14

Have the amended agreements or agreements incorporating the amendments been previously provided to the ATO?

na

15

Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

16

What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

na

17

What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

na

18

Please confirm that you have attached the amendments for previously provided agreements for this transaction/RAS

na

19

Filename(s) of the amended agreement(s)

na

20

Are there APAs or rulings provided by other jurisdictions for this transaction/RAS?

False

21

Which other Transaction IDs does that APA/ruling cover?

na

22

Has the reporting entity previously provided these APAs/rulings to the ATO?

na

23

Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

24

What is the filename of the APAs/Rulings previously provided to the ATO?

na

25

What is the year in which the reporting entity previously provided these APAs/rulings?

na

26

Please confirm that you have attached the relevant APAs/rulings for this transaction/RAS

na

27

Filename(s) of the APAs/Rulings

na

Table 3: Record 3 for Local File Part B using transaction focused reporting method

Question number

Question label

Response

1.

Transaction identifier

3

2.

Which transfer pricing/capital asset pricing methodology has the IRP relied on this transaction/RAS?

TNMM

3.

Is the reporting entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction/RAS?

False

4.

Is there a written agreement or other relevant document evidencing the terms of the agreement covering this transaction/RAS?

True

5.

Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction/RAS (as reported at Part A)?

False

6.

Other Transaction IDs covered by the agreement

1, 2

7.

Has the written agreement documentation been previously provided to the ATO?

False

8.

Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

n/a

9.

Title of the agreement(s) previously provided to the ATO

n/a

10.

What is the year in which the agreement(s) was previously provided to the ATO?

n/a

11

Please confirm that you have attached the agreements for this transaction/RAS

True

12

Filename(s) of IRP Agreement(s)

LFPBI_Intercompany_Supply_Agreement.pdf

13

Since providing the written agreement to the ATO, has the agreement been amended?

na

14

Have the amended agreements or agreements incorporating the amendments been previously provided to the ATO?

na

15

Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

16

What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

na

17

What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

na

18

Please confirm that you have attached the amendments for previously provided agreements for this transaction/RAS

na

19

Filename(s) of the amended agreement(s)

na

20

Are there APAs or rulings provided by other jurisdictions for this transaction/RAS?

False

21

Which other Transaction IDs does that APA/ruling cover?

na

22

Has the reporting entity previously provided these APAs/rulings to the ATO?

na

23

Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

24

What is the filename of the APAs/Rulings previously provided to the ATO?

na

25

What is the year in which the reporting entity previously provided these APAs/rulings?

na

26

Please confirm that you have attached the relevant APAs/rulings for this transaction/RAS

na

27

Filename(s) of the APAs/Rulings

na

Optional streamlined LFPB reporting method (one Part B record)

Aus Co can instead choose to adopt the optional streamlined LFPB method to reduce duplication as the transaction and agreement Part B information are all identical. If choosing this method, Aus Co only needs one Part B record for all 3 transaction IDs, provided all relevant transaction IDs are reported at Questions 1 and 6.

Using the streamlined LFPB method, Aus Co completes the questions as shown in the following table.

Table 4: Single consolidated Local File Part B record using streamlined LFPB reporting method

Question number

Question label

Response

1.

Transaction identifier

1

2.

Which transfer pricing/capital asset pricing methodology has the IRP relied on this transaction/RAS?

TNMM

3.

Is the reporting entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction/RAS?

False

4.

Is there a written agreement or other relevant document evidencing the terms of the agreement covering this transaction/RAS?

True

5.

Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction/RAS (as reported at Part A)?

False

6.

Other Transaction IDs covered by the agreement

2, 3

7.

Has the written agreement documentation been previously provided to the ATO?

False

8.

Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

n/a

9.

Title of the agreement(s) previously provided to the ATO

n/a

10.

What is the year in which the agreement(s) was previously provided to the ATO?

n/a

11

Please confirm that you have attached the agreements for this transaction/RAS

True

12

Filename(s) of IRP Agreement(s)

LFPBI_Intercompany_Supply_Agreement.pdf

13

Since providing the written agreement to the ATO, has the agreement been amended?

na

14

Have the amended agreements or agreements incorporating the amendments been previously provided to the ATO?

na

15

Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

16

What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

na

17

What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

na

18

Please confirm that you have attached the amendments for previously provided agreements for this transaction/RAS

na

19

Filename(s) of the amended agreement(s)

na

20

Are there APAs or rulings provided by other jurisdictions for this transaction/RAS?

False

21

Which other Transaction IDs does that APA/ruling cover?

na

22

Has the reporting entity previously provided these APAs/rulings to the ATO?

na

23

Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

24

What is the filename of the APAs/Rulings previously provided to the ATO?

na

25

What is the year in which the reporting entity previously provided these APAs/rulings?

na

26

Please confirm that you have attached the relevant APAs/rulings for this transaction/RAS

na

27

Filename(s) of the APAs/Rulings

na

Example 2: No written agreements or other relevant documentation covering the IRP transactions/RAS, all Part B transaction information identical

Hold Co reports 2 separate IRP transactions at Part A with unique transaction IDs. There is no written agreement or other relevant documentation covering the IRP transactions. The TP methodology and agreement details are identical across both transactions and there are no APAs or rulings covering these transactions.

Transaction focused reporting method (two Part B records)

If Hold Co chooses to use the transaction focused reporting method, one Part B record per transaction ID is required to be reported, with identical information repeated for each record.

Using the transaction focused reporting method, Hold Co completes the questions for Part B as shown in the following table.

Table 5: Record 1 for Local File Part B using transaction focused reporting method where no written agreement/other relevant documentation

Question number

Question label

Response

1.

Transaction identifier

9

2.

Which transfer pricing/capital asset pricing methodology has the IRP relied on this transaction/RAS?

TNMM

3.

Is the reporting entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction/RAS?

False

4.

Is there a written agreement or other relevant document evidencing the terms of the agreement covering this transaction/RAS?

False

5.

Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction/RAS (as reported at Part A)?

Na

6.

Other Transaction IDs covered by the agreement

2, 3

7.

Has the written agreement documentation been previously provided to the ATO?

False

8.

Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

n/a

9.

Title of the agreement(s) previously provided to the ATO

n/a

10.

What is the year in which the agreement(s) was previously provided to the ATO?

na

11

Please confirm that you have attached the agreements for this transaction/RAS

True

12

Filename(s) of IRP Agreement(s)

LFPBI_Intercompany_Supply_Agreement.pdf

13

Since providing the written agreement to the ATO, has the agreement been amended?

na

14

Have the amended agreements or agreements incorporating the amendments been previously provided to the ATO?

na

15

Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

16

What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

na

17

What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

na

18

Please confirm that you have attached the amendments for previously provided agreements for this transaction/RAS

na

19

Filename(s) of the amended agreement(s)

na

20

Are there APAs or rulings provided by other jurisdictions for this transaction/RAS?

False

21

Which other Transaction IDs does that APA/ruling cover?

na

22

Has the reporting entity previously provided these APAs/rulings to the ATO?

na

23

Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

24

What is the filename of the APAs/Rulings previously provided to the ATO?

na

25

What is the year in which the reporting entity previously provided these APAs/rulings?

na

26

Please confirm that you have attached the relevant APAs/rulings for this transaction/RAS

na

27

Filename(s) of the APAs/Rulings

na

Table 6: Record 2 for Local File Part B using transaction focused reporting method where no written agreement/other relevant documentation

Question number

Question label

Response

1.

Transaction identifier

10

2.

Which transfer pricing/capital asset pricing methodology has the IRP relied on this transaction/RAS?

TNMM

3.

Is the reporting entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction/RAS?

False

4.

Is there a written agreement or other relevant document evidencing the terms of the agreement covering this transaction/RAS?

False

5.

Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction/RAS (as reported at Part A)?

na

6.

Other Transaction IDs covered by the agreement

na

7.

Has the written agreement documentation been previously provided to the ATO?

False

8.

Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

n/a

9.

Title of the agreement(s) previously provided to the ATO

n/a

10.

What is the year in which the agreement(s) was previously provided to the ATO?

n/a

11

Please confirm that you have attached the agreements for this transaction/RAS

True

12

Filename(s) of IRP Agreement(s)

na

13

Since providing the written agreement to the ATO, has the agreement been amended?

na

14

Have the amended agreements or agreements incorporating the amendments been previously provided to the ATO?

na

15

Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

16

What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

na

17

What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

na

18

Please confirm that you have attached the amendments for previously provided agreements for this transaction/RAS

na

19

Filename(s) of the amended agreement(s)

na

20

Are there APAs or rulings provided by other jurisdictions for this transaction/RAS?

na

21

Which other Transaction IDs does that APA/ruling cover?

na

22

Has the reporting entity previously provided these APAs/rulings to the ATO?

na

23

Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

24

What is the filename of the APAs/Rulings previously provided to the ATO?

na

25

What is the year in which the reporting entity previously provided these APAs/rulings?

na

26

Please confirm that you have attached the relevant APAs/rulings for this transaction/RAS

na

27

Filename(s) of the APAs/Rulings

na

Optional streamlined LFPB reporting method (one Part B record)

Hold Co can instead choose to adopt the optional streamlined LFPB method to reduce duplication as the Part B information is all identical. If choosing this method, Hold Co only needs one Part B record for the 2 transaction IDs, provided all relevant transaction IDs are reported at Questions 1 and 6.

Table 7: Single consolidated Part B record using streamlined LFPB reporting method where no written agreement/other relevant documentation

Question number

Question label

Response

1.

Transaction identifier

9

2.

Which transfer pricing/capital asset pricing methodology has the IRP relied on this transaction/RAS?

TNMM

3.

Is the reporting entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction/RAS?

False

4.

Is there a written agreement or other relevant document evidencing the terms of the agreement covering this transaction/RAS?

False

5.

Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction/RAS (as reported at Part A)?

na

6.

Other Transaction IDs covered by the agreement

10

7.

Has the written agreement documentation been previously provided to the ATO?

False

8.

Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

n/a

9.

Title of the agreement(s) previously provided to the ATO

n/a

10.

What is the year in which the agreement(s) was previously provided to the ATO?

n/a

11

Please confirm that you have attached the agreements for this transaction/RAS

True

12

Filename(s) of IRP Agreement(s)

na

13

Since providing the written agreement to the ATO, has the agreement been amended?

na

14

Have the amended agreements or agreements incorporating the amendments been previously provided to the ATO?

na

15

Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

16

What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

na

17

What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

na

18

Please confirm that you have attached the amendments for previously provided agreements for this transaction/RAS

na

19

Filename(s) of the amended agreement(s)

na

20

Are there APAs or rulings provided by other jurisdictions for this transaction/RAS?

na

21

Which other Transaction IDs does that APA/ruling cover?

na

22

Has the reporting entity previously provided these APAs/rulings to the ATO?

na

23

Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

24

What is the filename of the APAs/Rulings previously provided to the ATO?

na

25

What is the year in which the reporting entity previously provided these APAs/rulings?

na

26

Please confirm that you have attached the relevant APAs/rulings for this transaction/RAS

na

27

Filename(s) of the APAs/Rulings

na

End of example

Example 3: Written agreement covers multiple transactions but Part B information is NOT identical as different transfer pricing methodologies apply to each transaction

ABC Co has a single written agreement covering 2 separate IRP transactions shown at Part A with unique transaction IDs. One transaction is for service fees and the other is for royalty fees. There are no APAs or rulings covering these transactions.

The IRP counterparty for each transaction has relied on a different transfer pricing methodology. In particular, the cost-plus (CP) method is used for the services transaction, and the comparable uncontrolled price method (CUP) applies for the royalties transaction. As the transaction information in Part B is not identical, these transactions can't be consolidated under the streamlined reporting method.

ABC Co completes the questions for Part B using the transaction focused method as shown in the following tables.

Transaction focused reporting method (multiple Part B records)
Table 8: Record 1 for Local File Part using transaction focused reporting method due to differing TP methodology (Cost-plus)

Question number

Question label

Response

1.

Transaction identifier

4

2.

Which transfer pricing/capital asset pricing methodology has the IRP relied on this transaction/RAS?

Cost plus

3.

Is the reporting entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction/RAS?

False

4.

Is there a written agreement or other relevant document evidencing the terms of the agreement covering this transaction/RAS?

False

5.

Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction/RAS (as reported at Part A)?

na

6.

Other Transaction IDs covered by the agreement

5

7.

Has the written agreement documentation been previously provided to the ATO?

False

8.

Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

9.

Title of the agreement(s) previously provided to the ATO

na

10.

What is the year in which the agreement(s) was previously provided to the ATO?

na

11

Please confirm that you have attached the agreements for this transaction/RAS

True

12

Filename(s) of IRP Agreement(s)

LFPBI_Intercompany_IP_Services_Agreement.pdf

13

Since providing the written agreement to the ATO, has the agreement been amended?

na

14

Have the amended agreements or agreements incorporating the amendments been previously provided to the ATO?

na

15

Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

16

What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

na

17

What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

na

18

Please confirm that you have attached the amendments for previously provided agreements for this transaction/RAS

na

19

Filename(s) of the amended agreement(s)

na

20

Are there APAs or rulings provided by other jurisdictions for this transaction/RAS?

False

21

Which other Transaction IDs does that APA/ruling cover?

na

22

Has the reporting entity previously provided these APAs/rulings to the ATO?

na

23

Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

24

What is the filename of the APAs/Rulings previously provided to the ATO?

na

25

What is the year in which the reporting entity previously provided these APAs/rulings?

na

26

Please confirm that you have attached the relevant APAs/rulings for this transaction/RAS

na

27

Filename(s) of the APAs/Rulings

na

Table 9: Record 2 for Local File Part B using transaction focused reporting method due to different TP methodology (CUP)

Question number

Question label

Response

1.

Transaction identifier

5

2.

Which transfer pricing/capital asset pricing methodology has the IRP relied on this transaction/RAS?

CUP

3.

Is the reporting entity not able to obtain information from the IRP for the transfer pricing methodology the IRP relied upon for this transaction/RAS?

False

4.

Is there a written agreement or other relevant document evidencing the terms of the agreement covering this transaction/RAS?

False

5.

Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction/RAS (as reported at Part A)?

na

6.

Other Transaction IDs covered by the agreement

4

7.

Has the written agreement documentation been previously provided to the ATO?

False

8.

Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

9.

Title of the agreement(s) previously provided to the ATO

na

10.

What is the year in which the agreement(s) was previously provided to the ATO?

na

11

Please confirm that you have attached the agreements for this transaction/RAS

True

12

Filename(s) of IRP Agreement(s)

LFPBI_Intercompany_IP_Services_Agreement.pdf

13

Since providing the written agreement to the ATO, has the agreement been amended?

na

14

Have the amended agreements or agreements incorporating the amendments been previously provided to the ATO?

na

15

Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

16

What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

na

17

What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

na

18

Please confirm that you have attached the amendments for previously provided agreements for this transaction/RAS

na

19

Filename(s) of the amended agreement(s)

na

20

Are there APAs or rulings provided by other jurisdictions for this transaction/RAS?

False

21

Which other Transaction IDs does that APA/ruling cover?

na

22

Has the reporting entity previously provided these APAs/rulings to the ATO?

na

23

Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

na

24

What is the filename of the APAs/Rulings previously provided to the ATO?

na

25

What is the year in which the reporting entity previously provided these APAs/rulings?

na

26

Please confirm that you have attached the relevant APAs/rulings for this transaction/RAS

na

27

Filename(s) of the APAs/Rulings

na

End of example

QC107831