IRPD methodology
IRPD statistics is based on cleansed IRPD data as at 31 October 2023, combining data from processed IDS and LFPA lodgments.
The IRPD statistics in IRPD statistics 2021–22 reflect the most complete picture of total IRPDs.
To meet privacy and confidentiality requirements, some items may be aggregated with other items or not included.
Totals in tables and charts may differ from the sum of components due to rounding.
Data sources
International dealings schedule (IDS)
Companies, partnerships, trusts with IRPDs greater than $2 million are required to lodge an IDS. For small business entities there is a higher threshold of the lesser of $5 million or 50% of aggregated turnover. IRPDs are disclosed by IRPD type in the aggregate at Section A of the IDS.
Local file – part A (LFPA)
Country-by-country (CBC) reporting entities are required to lodge country-by-country (CBC) reporting statements, which include the local file.
The local file includes part A (LFPA), which collects IRPD data for individual IRP transactions, at a more detailed level than the aggregated IRPD data in the IDS.
Where statistics are sourced from the LFPA, IRPD data is aggregated to the taxpayer level, to align with IDS reporting.
Administrative solution
The local file administrative solution (admin solution) can be chosen by CBC reporting entities to minimise duplicated IRPD reporting in the IDS and LFPA:
- If a CBC reporting entity chooses to lodge the LFPA at the same time as the tax return, the IRPD labels at questions 2 to 17 in Section A of the IDS do not need to be completed.
- Alternatively, if the admin solution is not adopted, CBC reporting entities are generally required to disclose IRPDs in the IDS and the LFPA.
Where a CBC reporting entity has not adopted the admin solution, statistics may be sourced from the IDS or the LFPA, depending on the nature of the IRPD statistic and other considerations.
Hybrid IRPD data
The statistics in IRPD statistics are sourced from curated, hybrid population datasets that combine IRPD data from IDS and LFPA lodgments.
General IRPD statistics
- Where Section A of the IDS has been completed, IRPD data from the IDS is generally used, instead of the LFPA.
- Where Section A of the IDS has not been completed, a 'reconstruction' of IDS data for IRPDs (at the taxpayer level) is derived from LFPA data.
|
Taxpayer |
Section A |
LFPA |
IRPD data source |
|---|---|---|---|
|
The Trustee for 123 Trust |
✔ |
✘ |
Reported IDS data |
|
ABC Pty Ltd |
✘ |
✔ |
Reconstructed IDS data |
|
XYZ Limited |
✔ |
✔ |
Reported IDS data |
- The Trustee for 123 Trust is not required to lodge an LFPA because it is not a CBC reporting entity. The taxpayer's IRPDs are sourced from Section A of the IDS.
- ABC Pty Ltd has adopted the local file administrative solution. As the taxpayer has not completed Section A of the IDS, the taxpayer's IRPDs are sourced from reconstructed IDS data derived from the LFPA.
- XYZ Limited is a CBC reporting entity that did not adopt the admin solution. The taxpayer disclosed IRPDs in Section A of the IDS, and subsequently lodged an LFPA. The taxpayer's IRPDs are sourced from Section A of the IDS.
IRPD statistics by jurisdiction
- Where an LFPA has been lodged, IRPD data from the LFPA is generally used, instead of the IDS. The LFPA collects jurisdictional data for all IRPDs.
- Where an LFPA has not been lodged, the IRPD data at questions 3 to 4 in Section A of the IDS is used. IDS reporting at these questions is limited to a subset of countries with the highest dollar value of IRPDs.
|
Taxpayer |
Section A |
LFPA |
Jurisdictional data source |
|---|---|---|---|
|
The Trustee for 123 Trust |
✔ |
✘ |
Reported IDS data |
|
ABC Pty Ltd |
✘ |
✔ |
LFPA jurisdictional data |
|
XYZ Limited |
✔ |
✔ |
LFPA jurisdictional data |
- The Trustee for 123 Trust is not required to lodge an LFPA because it is not a CBC reporting entity. The taxpayer's IRPDs are sourced from Section A of the IDS, noting that the jurisdiction of all IRPDs may not be disclosed.
- ABC Pty Ltd has adopted the local file administrative solution. The taxpayer's IRPDs by jurisdiction are sourced from the LFPA.
- XYZ Limited is a CBC reporting entity that did not adopt the admin solution. The taxpayer disclosed IRPDs in Section A of the IDS and subsequently lodged an LFPA. The taxpayer's IRPDs by jurisdiction are sourced from the LFPA, which discloses the jurisdiction of all IRPDs.
Data cleansing and other issues
Data cleansing
Some IRPD data from the LFPA and IDS is affected by a range of reporting and other data integrity issues, the impact of which can be pronounced for the LFPA because IRPDs are reported at the transaction level.
As part of the compilation of IRPD statistics, cleansing procedures have been applied to IRPD data to remediate these issues where possible. Many of the most significant revisions have been applied after consultation with concerned entities.
Examples of data integrity issues include:
- transcription errors
- typographical errors involving similar country codes
- transposition errors which overstate or understate reported IRPDs
- other unintentional misreporting, where IRPDs haven't been disclosed correctly.
Authorised deposit-taking institutions (ADIs)
IRPD statistics excludes data reported by authorised deposit-taking institutions (ADIs), and foreign banks and branches (banks).
We exclude these records, which relate to a small number of entities, to present a more meaningful overview of statistics for IRPDs.
The dealings reported by these entities can distort or skew IRPD statistics because:
- banking operations may involve more extensive overseas branch operations than for other industries – the obligation to report, or to not report, dealings between offshore branches and overseas related entities in any particular year may depend on a range of specific factual circumstances and tax rules
- transitional and special reporting rules apply to local file reporting for banks
- data quality issues.
Taxation statistics
We also publish IRPD statistics in Taxation statistics 2021–22.
When analysing IRPD statistics, you should be aware that:
- Taxation statistics also provides non-IRPD statistics from the IDS.
- Taxation statistics provides limited IRPD statistics from the IDS for the 2012–13 to 2017–18 income years. However, the IRPD statistics in Taxation statistics 2021–22 exclude IRPDs reported in the LFPA, where the majority of IRPDs (by dollar value) are now disclosed.
- IRPD statistics provides IRPD statistics for the 2015–16 income year onwards. The IRPD statistics in IRPD statistics 2021–22
- include IRPDs reported in the IDS and LFPA
- are curated to minimise the impact of legislative and reporting changes
- reflect comprehensive data cleansing to address data integrity issues.
Other relevant publications
Schedules and instructions
Taxation statistics
Definitions
IDS
International dealings schedule
IRP
IRPDs
International related party dealings
IRPD type
The type of IRPD based on:
- transaction category groupings or transaction categories in the LFPA
- equivalent questions/labels in Section A of the IDS (International related party dealings).
The following table summarises the IRPD types presented in these statistics, along with the LFPA transaction category groupings and IDS questions used.
|
IRPD type |
LFPA transaction category grouping |
IDS question(s) |
|---|---|---|
|
Tangible property of a revenue nature |
||
|
Royalties and licence fees |
||
|
Rent and leasing |
||
|
Service arrangements |
||
|
Interest |
IRPD debt interests (including ordinary loans and borrowings) |
|
|
Guarantees |
||
|
Insurance |
||
|
Reinsurance |
||
|
Derivatives |
||
|
Other financial |
||
|
Share-based employee remuneration |
||
|
Other IRPDs |
IRP expenditure
Expenditure incurred for IRPDs, including capitalised interest deducted.
For the purposes of these statistics, IRPD expenditure generally excludes:
- consideration paid for IRPDs of a non-revenue (capital) nature
- foreign exchange losses deducted for IRPDs.
IRP revenue
Revenue earned or derived from IRPDs, including capitalised interest returned.
For the purposes of these statistics, IRPD revenue generally excludes:
- consideration received for IRPDs of a non-revenue (capital) nature
- foreign exchange gains returned for IRPDs.
Jurisdiction
The country or jurisdiction in which the non-resident counterparty to an IRPD is located.
For the purposes of the LFPA, jurisdiction is based on either:
- the country of the permanent establishment of the IRP (if applicable), otherwise
- the country of tax residence of the IRP.
LFPA
Local file – part A. An LFPA must be lodged by country-by-country (CBC) reporting entities with IRPDs for income years from 1 January 2016, unless exempted or excluded.