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Appendices

Last updated 21 April 2020

Appendix A: Glossary

Table 18: Glossary

Term

Meaning

Assignment

Assignment in law or in equity, including without limitation assignment by declaration of trust

Australian entity

An entity which is an Australian resident for tax purposes

Controlled transactions

Dealings with an International related parties (IRPs)

Debts

Debt receivables including loan receivables

Debt interest

A debt interest under Division 974 of the ITAA 1997

Equity interest

An equity interest under Division 974 or section 820-930 of the ITAA 1997

Foreign entity

Any entity which is not an Australian resident for tax purposes

International related party

See What is an IRP and IRPD?

Intellectual Property (IP)

Trademark, patent, design, copyright, other intellectual property or similar property or rights

International related party dealings (IRPD)

See What is an IRP and IRPD?

Ordinary shares

Shares issued by a company carrying proportionate rights to voting and to profit and capital distributions, and carrying no special rights

Short form exceptions list

List of kinds of transactions, that if entered into by the Reporting Entity will mean it will not be eligible to complete the short form local file

Relevant Agreement Series

As described in: Local file – Part B: Guidance on providing International Related Party agreements

Appendix B: Transaction categories

Table 19: IRPDs in tangible property of a revenue nature

Code

Value

TPRN

Tangible property of a revenue nature

Table 20: IRPD service arrangements

Code

Value

TRS

Treasury-related services

MAS

Management and administration services

INSERV

Insurance services

REINSERV

Reinsurance services

RD

Research and development services

SAM

Sales and marketing services

SITS

Software and IT services

TS

Technical services

LS

Logistics services

AM

Asset management services

OS

Other services

Table 21: IRPD use rights

Code

Value

RUIP

Rights to use IP

ORSR

Other rights to use, supply or receive where consideration is royalty under section 6(1) of the ITAA 1936

LF

Licence fees

RRP

Rent of real property

HLPE

Hire or lease of plant or equipment

LHORP

Lease or hire of other property or rights

Table 22: IRPD share-based employment remuneration

Code

Value

SBER

Share based employment remuneration

Table 23: Other revenue (non-financial) IRPDs

Code

Value

CCA

Cost contribution arrangement

ORIRPD

Other revenue IRPDs

Table 24: IRPD derivative transactions

Code

Value

CCIRS

Cross currency interest rate swap

CDCSFFO

Currency derivative (not cross currency interest rate swap), including currency swap, forward, future or option

FFIRS

Fixed for floating interest rate swap (not cross currency)

OIRD

Other interest rate derivative (not cross currency)

CDS

Credit default swap

AS

Asset swap

CDCS

Commodity derivative, including commodity swap, forward, future or option

OD

Other derivative

Table 25: IRPD debt interests (including ordinary loans and borrowings)

Code

Value

OBL

Ordinary borrowings / loans (excluding trade financing)

TFIN

Trade financing

BND

Bonds

PNOT

Promissory notes

CNTDI

Convertible notes that are debt Interests

CSTDI

Convertible shares that are debt Interests

RPSDI

Redeemable preference shares that are debt Interests

OKDI

Other kinds of debt Interests

Table 26: IRPD debt factoring or debt securitisation

Code

Value

IDF

Inward debt factoring

ODF

Outward debt factoring

IDSEC

Inward debt securitisation

ODSEC

Outward debt securitisation

Table 27: Other kinds of IRPDs of a financial nature

Code

Value

GILDI

Guarantee or indemnity of liability under debt Interest

GIOKL

Guarantee or indemnity of other kind of liability

IN

Insurance

REIN

Reinsurance

OFD

Other financial dealings

Table 28: IRPDs involving disposal or acquisition of tangible property of a non-revenue (capital) nature

Code

Value

RPRT

Real property

PLEQ

Plant or equipment

OTPRTY

Other tangible property

Table 29: IRPDs involving disposal or acquisition of intangible property or rights of a non-revenue (capital) nature

Code

Value

ASIP

Assignment of IP

IOSH

Issue of ordinary shares

AOSH

Assignment of ordinary shares

IEIOOS

Issue of equity interest other than ordinary shares

AQIOS

Assignment of equity interest other than ordinary Shares

ASSD

Assignment of debts

ASSL

Assignment of liabilities

ASSBC

Assignment of benefit of contracts (excluding assignment of equity interests, debts or IP)

ASSOPR

Assignment of other intangible property or rights

Table 30: Foreign Exchange IRPDs

Code

Value

FCDSTTS

Foreign currency deferred payment arrangement for sale of Tangible Trading Stock

FCDPTTS

Foreign currency deferred payment arrangement for purchase of Tangible Trading Stock

FCDAPS

Foreign currency deferred payment arrangement for provision of Services

FCDAAS

Foreign currency deferred payment arrangement for acquisition of Services

FCDRRP

Foreign currency deferred payment arrangement for rent of real property to IRP

FCDRRPI

Foreign currency deferred payment arrangement for rent of real property from IRP

FCDHLP

Foreign currency deferred payment arrangement for hire or lease of plant or equipment to IRP

FCDHLPE

Foreign currency deferred payment arrangement for hire or lease of plant or equipment from IRP

FCDSBER

Foreign currency deferred payment arrangement for share based employment recharge to IRP

FCDSBERI

Foreign currency deferred payment arrangement for share based employment recharge from IRP

Appendix C: TP method / CAP method

Table 31: Appendix C

Code

Value

APPC

Apportionment of costs

APPI

Apportionment of Income

CUP

Comparable uncontrolled price method

CCA

Cost-contribution arrangement

CP

Cost-plus method

FMUAC

Fixed mark-up applied to cost

FPRP

Fixed percentage of resale price

MC

Marginal costing

PS

Profit split method

RPM

Resale price method

TNM

Transactional net margin method

TNMW

Transactional net margin method (whole-of-entity)

OTH

Other arm's length methods

NON

None

UNKT

Unknown (transfer pricing method)

CPR

Cost Price

DVAL

Directors valuation

DCF

Discounted cash flow

IVAL

Independent valuation

NCON

Nil consideration

QMRP

Quoted market price

WDVAL

Written-down value

OM

Other methods

UNKC

Unknown (capital asset pricing method)

Appendix D: TP documentation codes / STPRK options

Table 32: Appendix D

Code

Value

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%

7

Simplified transfer pricing record keeping (materiality)

8

Simplified transfer pricing record keeping (small taxpayers)

9

Simplified transfer pricing record keeping (distributors)

10

Simplified transfer pricing record keeping (intra-group services)

11

Simplified transfer pricing record keeping (management & administration services)

12

Simplified transfer pricing record keeping (technical services)

13

Simplified transfer pricing record keeping (low level loans – inbound)

14

Simplified transfer pricing record keeping (low level loans – outbound)

15

Green Zone (PCG 2017/1)

16

Green Zone (PCG 2017/4)

Appendix E: Exclusion list

Table 33: Appendix E

Code

Value

STPRKIGS

Simplified transfer pricing record keeping (intra-group services)

STPRKMAS

Simplified transfer pricing record keeping (management & administration services)

STPRKTS

Simplified transfer pricing record keeping (technical services)

STPRKLLI

Simplified transfer pricing record keeping (low level loans – inbound)

STPRKLLO

Simplified transfer pricing record keeping (low level loans – outbound)

RUESA

Reimbursement under Employee secondment agreements

LVLRSA

Low value / low risk service agreements

LVLRSPT

Low value / low risk sale and purchase tangible trading Stock agreements

IOS

Issue of ordinary shares

QC59433