Any amounts provided at any of the below questions should be reported in whole dollars and cents.
Find out about:
- The meaning of Foreign currency deferred payment arrangements (FCDPA) in Appendix 9
- The special rules for Reporting FX gains and losses for FCDPA in Appendix 7.
- How a FCDPA transaction will no longer be in existence when all amounts payable under the underlying IRPD transaction/RAS have been satisfied, including through an intercompany loan with an IRP (which would need to be separately reported as an IRPD Debt Interests transaction).
- 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.
For FDCPA transactions, related or directly connected transactions will include the underlying IRPD transaction/RAS which gives rise to the foreign currency payment obligation that was due and outstanding.
(LCMSF206)
- What is the transaction category?
Select the transaction category for the IRPD transaction.
(LCMSF32)
- Is this transaction part of a RAS?
Always indicate False.
The specific FCDPA transaction categories enable the reporting entity to include longer term FCDPA arising from more than one underlying IRPD transaction/RAS in a single reported FDCPA transaction if the underlying IRPD transactions/RAS are:
- with the same IRP counterparty, and
- of the same relevant type so all the FCDPA for the underlying IRPD transactions/RAS are covered by the same FCDPA transaction category.
For example, if the reporting entity has reported tangible goods purchased from the same IRP under two separate TPRN transactions/RAS, and there are longer term FCDPA during the income year for both of the reported TPRN transactions/RAS, the reporting entity may choose to report these FCDPAs as a single FCDPTTS transaction (Foreign currency deferred payment arrangement for purchase of Tangible Trading Stock) in Part A.
The specific FCDPA transaction categories do not allow longer term FCDPA for payments to an IRP under underlying IRPD transactions/RAS to be covered by the same FCDPA transaction category as longer term FCDPA for payments from the IRP under other IRPD transactions/RAS. For example, longer term FCDPA for payments owing by the reporting entity for tangible goods purchased from the IRP cannot be included in the same reported FCDPA transaction category as longer term FCDPA for payments owing to the reporting entity by the IRP for tangible goods sold to the IRP.
(LCMSF33)
- How many transactions are part of the RAS?
Not applicable
(LCMSF35)
- Australian counterparty name
Show the full name of the Australian counterparty (which may be the reporting entity itself) to this transaction.
(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.
(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.
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 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. 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 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 during the income year.
Do not show:
- any reduction in amounts payable by the reporting entity under the FCDPA during the income year
- any increase in amounts receivable by the reporting entity under the FCDPA 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 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 during the income year.
Do not show:
- any increase in amounts payable by the reporting entity under the FCDPA during the income year
- any reduction in amounts receivable by the reporting entity under the FCDPA 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 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 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 during the income year based on the reporting entity’s accounting records.
Show the amount of any interest charged to or payable by the reporting entity in respect of the FCDPA and any other expenditure not of a capital nature for income tax purposes based on the reporting entity’s accounting records, excluding interest that has been capitalised 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 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 during the income year based on the reporting entity’s accounting records.
Show the amount of any interest charged by or payable to the reporting entity in respect of the FCDPA and any other revenue not of a capital nature for income tax purposes based on the reporting entity’s accounting records, excluding interest that has been capitalised 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)
- Average balance of debt interests issued (Inbound Borrowings)
Show the average quarterly balance owing by the reporting entity to the IRP for the FCDPA during the income year:
- add up the amount owing by the reporting entity to the IRP for the FCDPA based on the reporting entity’s accounting records at the start of the year and the amount owing by the reporting entity to the IRP for the FCDPA based on the reporting entity’s accounting records at the end of each quarter
- divide the result by five.
Only positive amounts should be reported. For example, any amount owing shown in your accounts as a negative amount should be reported as a positive amount equivalent to the average amount owing or outstanding for the FCDPA.
(LCMSF210)
- Capitalised interest deducted
Show the amount of any capitalised interest deducted for Australian income tax purposes for the amount owing by the reporting entity for the FCDPA for the income year.
Show zero if there is no capitalised interest deducted for the amount owing by the reporting entity for the FCDPA.
(LCMSF211)
- Average balance of debt interests held (Outbound Loans)
Show the average quarterly balance owing to the reporting entity by the IRP for the FCDPA during the income year:
- add up the amount owing to the reporting entity to the IRP for the FCDPA based on the reporting entity’s accounting records at the start of the year and the amount owing to the reporting entity to the IRP for the FCDPA based on the reporting entity’s accounting records at the end of each quarter
- divide the result by five.
(LCMSF212)
- Capitalised interest returned
Show the amount of any capitalised interest returned for Australian income tax purposes for the amount owing to the reporting entity for the FCDPA for the income year.
Show zero if there is no capitalised interest returned for the amount owing to the reporting entity for the FCDPA.
(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 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 during the income year.
Otherwise indicate False.
(LCMSF45)
- Is the debt interest (including borrowing/loan) interest-free?
Indicate True if there is no interest charged or payable for the FCDPA.
Indicate False if there is interest charged or payable for the FCDPA.
Whether the FCDPA is interest-free is determined by reference to the overall obligations and rights arising over the whole period the FCDPA is, or is expected to be, on foot. It is not just determined by reference to whether interest is charged or payable in a particular income year
(LCMSF237)
- Did you enter into a deferred foreign currency payment arrangement in relation to this transaction?
Not applicable.
(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 the FCDPA 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 the FCDPA for the income year.
(LCMSF87)
- Foreign Currency Code
Show the Foreign Currency CodeExternal Link in relation to foreign exchange losses deducted for the FCDPA.
(LCMSF219)
- 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 the FCDPA 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 the FCDPA.
(LCMSF43)
- Foreign Currency Code
Show the Foreign Currency CodeExternal Link in relation to foreign exchange gains returned for the FCDPA.
(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 the FCDPA.
For a FCDPA transaction, Question 33 is referring to the FCDPA financing arrangement which results from deferral of payment of an amount of foreign currency owing under another underlying IRP transaction. Question 33 is not referring to the underlying non-financing IRPD transaction. For example, if there is a reported FCDPTTS transaction because there was a FCDPA for the sale price due and owing under an IRP commodity sale transaction, Question 33 is not referring to the IRP commodity sale transaction. It is instead referring to the financing arrangement which results from not satisfying the payment obligation.
(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 IRPD FCDPA transaction for which the reporting entity has prepared relevant transfer pricing documentation, expressed as a percentage of total dollar value of this transaction. It is not referring to transfer pricing documentation prepared for the underlying non-financing IRPD transaction. For example, if there is a reported FCDPTTS transaction because there was a FCDPA for the sale price due and owing under an IRP commodity sale transaction, Question 34 is not referring to transfer documentation for the IRP commodity sale transaction. It is instead referring to any transfer documentation for the financing arrangement which results from not satisfying the payment obligation.
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%
(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.
(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.
(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.
(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 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?
Always indicate False.
For a FCDPA transaction, Question 39 is referring to the FCDPA financing arrangement which results from deferral of payment of an amount of foreign currency owing under another underlying IRP transaction. Question 39 is not referring to the underlying non-financing IRP transaction. For example, if there is a reported FCDPTTS transaction because there was a FCDPA for the sale price due and owing under an IRP commodity sale transaction, Question 39 is not referring to the IRP commodity sale transaction. It is instead referring to the financing arrangement which results from not satisfying the payment obligation.
(LCMSF48)
- What category of the exclusions list applies to this transaction/RAS?
Not applicable.
(LCMSF49)
- Transaction Comments
Provide any relevant comments in respect of the transaction.
(LCMSF222)
Reporting examples: IRPD foreign currency deferred payment arrangements
Example 18: Longer term foreign currency deferred payment arrangements arising from purchase of homeware goods from Irish IRP
The facts are the same facts as Example 3.
No interest was charged to or payable by Aus Co for its outstanding payment obligations under the sale and purchase agreements with Ireland Co.
AusCo returned assessable foreign exchange gains of $150,000 and deducted foreign exchange losses of $400,000 under Subdivision 775-B of the ITAA 1997 during the income year, as a result of fluctuations in the AUD/USD exchange rate, in respect of US$12 million of payments outstanding for more than 12 months for purchases from Ireland Co.
The Australian dollar equivalent of the relevant US dollar payment obligations on the date of billing was A$15 million as recorded in Aus Co’s accounting records. The average quarterly balance of the amounts owing by Aus Co under these foreign currency deferred payment arrangements during the income year was A$9 million, reflecting the partial satisfaction of the amounts owing during the income year.
Aus Co has not applied a transfer pricing method to the foreign currency deferred payment arrangements.
Aus Co has not prepared transfer pricing documentation for the foreign currency deferred payment arrangements.
In accordance with the instructions for IRPDs in Tangible property of a revenue nature, Aus Co has completed the Questions for the connected purchase of goods transactions/RAS as shown at Table 4 in Example 3.
In accordance with the instructions for IRPD foreign currency deferred payments arrangements, Aus Co completes the Questions for the foreign currency deferred payment arrangements transaction based on its accounting records as shown in the following table.
|
Question no. |
Question label |
Response |
|---|---|---|
|
1 |
Transaction Identifier |
[Transaction ID] |
|
2 |
Related Transaction Identifier(s) |
[Transaction IDs for TPRN transactions in Table 4 in Example 3] |
|
3 |
Transaction category |
FCDPTTS |
|
4 |
Is this transaction part of a RAS? |
Na |
|
5 |
How many transactions are part of the RAS? |
Na |
|
6 |
Australian counterparty name |
Aus Co |
|
7 |
ABN or TFN of the Australian counterparty to the transaction/RAS |
[ABN or TFN] |
|
8 |
Name of IRP the non-resident counterparty to the transaction/RAS |
Ireland Co |
|
9 |
Tax residence of the IRP non-resident counterparty to the transaction/RAS |
IE |
|
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 |
0 |
|
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 |
0 |
|
18 |
Average balance of debt interests issued (Inbound Borrowings) |
9000000 |
|
19 |
Capitalised interest deducted |
0 |
|
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? |
False |
|
25 |
Is the debt interest (including borrowing/loan) interest-free? |
True |
|
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 |
400000 |
|
30 |
Foreign Currency Code |
USD |
|
31 |
Amount of foreign exchange gains returned for the transaction/RAS |
150000 |
|
32 |
Foreign Currency Code |
USD |
|
33 |
What transfer pricing/capital asset pricing methodology has been applied to the transaction/RAS? |
UNKT |
|
34 |
What level of transfer pricing documentation has been prepared for this transaction/RAS? |
1 |
|
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