Appendices

Last updated 25 April 2018

Appendix 1: Exclusion list and codes

Table 58: Exclusion list and codes
Code	Exclusion list
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)
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

Appendix 2: Accounting records / income tax records

Table 59: Accounting records / income tax records
Code	Transaction category	Accounting records / income tax records
TPRN	Tangible property of a revenue nature	Accounting records
RUIP	Rights to use IP	Income tax records
ORSR	Other rights to use, supply or receive where consideration is royalty under section 6(1) of the ITAA 1936	Income tax records
LF	Licence fees	Income tax records
RRP	Rent of real property	Accounting records
HLPE	Hire or lease of plant or equipment	Accounting records
LHORP	Lease or hire of other property or rights	Accounting records
TRS	Treasury related services	Accounting records
MAS	Management and administration services	Accounting records
INSERV	Insurance services	Accounting records
REINSERV	Reinsurance services	Accounting records
RD	Research and development services	Accounting records
SAM	Sales and marketing services	Accounting records
SITS	Software and IT services	Accounting records
TS	Technical services	Accounting records
LS	Logistics services	Accounting records
AM	Asset management services	Accounting records
OS	Other services	Accounting records
CCIRS	Cross currency interest rate swap	Accounting records
CDCSFFO	Currency derivative (not cross currency interest rate swap), including currency swap, forward, future or option	Accounting records
FFIRS	Fixed for floating interest rate swap (not cross currency)	Accounting records
OIRD	Other interest rate derivative (not cross currency)	Accounting records
CDS	Credit default swap	Accounting records
AS	Asset swap	Accounting records
CDCS	Commodity derivative, including commodity swap, forward, future or option	Accounting records
OD	Other derivative	Accounting records
IDF	Inward debt factoring	Accounting records
ODF	Outward debt factoring	Accounting records
IDSEC	Inward debt securitisation	Accounting records
ODSEC	Outward debt securitisation	Accounting records
OBL	Ordinary borrowings/loans (excluding trade financing)	Accounting records
TFIN	Trade financing	Accounting records
BND	Bonds	Accounting records
PNOT	Promissory notes	Accounting records
CNTDI	Convertible notes that are debt interests	Accounting records
CSTDI	Convertible shares that are debt interests	Accounting records
RPSDI	Redeemable preference shares that are debt interests	Accounting records
OKDI	Other kinds of debt interests	Accounting records
GILDI	Guarantee or indemnity of liability under a debt interest	Accounting records
GIOKL	Guarantee or indemnity of other kind of liability	Accounting records
IN	Insurance	Accounting records
REIN	Reinsurance	Accounting records
OFD	Other financial dealings	Accounting records
ORIRPD	Other revenue IRPDs	Accounting records
RPRT	Real property	Accounting records
PLEQ	Plant or equipment	Accounting records
OTPRTY	Other tangible property	Accounting records
ASIP	Assignment of IP	Accounting records
IOSH	Issue of ordinary shares	Accounting records
AOSH	Assignment of ordinary shares	Accounting records
IEIOOS	Issue of equity interest other than ordinary shares	Accounting records
AQIOS	Assignment of equity interest other than ordinary shares	Accounting records
ASSD	Assignment of debts	Accounting records
ASSL	Assignment of liabilities	Accounting records
ASSBC	Assignment of benefit of contracts (excluding assignment of equity interests, debts or IP)	Accounting records
ASSOPR	Assignment of other intangible property or rights	Accounting records
SBER	Share based employment remuneration	Income tax records
CCA	Cost contribution arrangement	Accounting records

Appendix 3: Assessable foreign exchange gains and deductible foreign exchange losses for Australian income tax

If the reporting entity has returned foreign exchange gains or deducted foreign exchange losses for its relevant IRP transaction/RAS for Australian income tax purposes, you need to show the amounts returned and deducted at Questions 15 and 16 in Part A of the local file for the relevant IRP transaction/RAS.

This may include foreign exchange gains the reporting entity has returned and foreign exchange losses it has deducted during the income year for trade-related financial liabilities or receivables which may potentially arise if the reporting entity did not pay the IRP, or was not paid by the IRP, when the price for goods or fees for services are payable.

Examples include:

foreign currency intercompany liabilities for amounts payable by the reporting entity for purchase of commodities from international related parties which are satisfied during the income year
foreign currency intercompany receivables for amounts payable to the reporting entity for provision of services to international related parties which are satisfied during the income year.

Assessable foreign exchange gains and deductible foreign exchange losses for income tax purposes are determined under Division 775 of the ITAA 1997 or, if applicable, under the taxation of financial arrangements (TOFA) provisions in Division 230 of the ITAA 1997.

For more guidance on entities covered by TOFA and the operation of TOFA, refer to Guide to the taxation of financial arrangements (TOFA).

In other scenarios assessable foreign exchange gains and deductible foreign exchange losses are determined under the provisions in Subdivisions 775-B to 775-E and Subdivisions 960-C and 960-D of the ITAA 1997.

Foreign exchange gain refers to a foreign exchange gain attributable to fluctuations in a currency exchange rate you make as a result of a forex realisation event under the provisions.

Foreign exchange loss refers to a foreign exchange loss attributable to fluctuations in a currency exchange rate you make as a result of a forex realisation event under the provisions.

Under Subdivision 775-B of the ITAA 1997 there are five main types of forex realisation events:

Forex realisation event 1 happens if you dispose of foreign currency, or a right to receive foreign currency, to another entity.
Forex realisation event 2 happens if you cease to have a right to receive foreign currency (other than because you disposed of the right to another entity).
Forex realisation event 3 happens if you cease to have an obligation to receive foreign currency.
Forex realisation event 4 happens if you cease to have an obligation to pay foreign currency.
Forex realisation event 5 happens if you cease to have a right to pay foreign currency.

There are also special rules:

under Subdivision 775-C of the ITAA 1997, for rollover for facility agreements and special rules for securities issued under the facility agreements
under Subdivision 775-D of the ITAA 1997, providing an election to disregard forex realisation events 2 and 4 for qualifying forex accounts not exceeding $250,000
under Subdivision 775-E of the ITAA 1997, providing a choice to use the retranslation method for qualifying forex accounts instead of forex realisation events 2 and 4.

For more information about foreign exchange gains and losses, see Foreign exchange gains and losses.

Appendix 4: Glossary

Table 60: 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
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 and section 820-930 of the ITAA 1997
Foreign entity	Any entity which is not an Australian resident for tax purposes
Highest quality financial accounts	The reporting entity's financial reports that report on the reporting entity's assets, liabilities, equity, income, expenses and cashflows (excluding assets, liabilities, equity, income, expenses and cashflows of other entities which are not members of the reporting entity's consolidated or MEC group for Australian tax purposes) for the income year, including where relevant more than one set of reports, which satisfy the following requirements: If there are general purpose financial reports prepared in accordance with AASB, IFRS or US GAAP, those reports. In the case of a reporting entity which is a member of a foreign owned global group, if there are no reports satisfying the requirements in 1, but there are group reporting packs submitted to the reporting entity's overseas global group entities for the purpose of preparing consolidated financial statements and/or central reporting, those reports. If there are no reports satisfying the requirements in 1or 2, but there are other reports including but not limited to separate financial statements or special purpose financial statements prepared in accordance with AASB, IFRS or USGAAP, those reports. If there are no reports satisfying the requirements in 1, 2, or 3, but there are management accounts, those reports. If there are no reports satisfying the requirements in 1, 2, 3 or 4, but there are other reports, those reports.
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 dealings schedule (IDS)	The International dealings schedule, being the income tax return schedule required to be completed as part of the company tax return, partnership tax return, trust tax return or attribution managed investment trust (AMIT) tax return if certain criteria are met
International related party dealings (IRPD)	As defined in the IDS instructions
OBU	An offshore banking unit under subsection 128AE(2) of the ITAA 1936 or section 717-710 of the ITAA 1997
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

QC52807

Appendices

Appendix 1: Exclusion list and codes

Appendix 2: Accounting records / income tax records

Appendix 3: Assessable foreign exchange gains and deductible foreign exchange losses for Australian income tax

Appendix 4: Glossary

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