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IRPD foreign currency deferred payment arrangements

Last updated 7 April 2021

Table 58: IRPD foreign currency deferred payment arrangements

Code

Description of transaction category

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

  1. Transaction Identifier

Show the Transaction ID for the transaction being reported.

(LCMSF31)

  1. Related Transaction Identifier(s)

Show all Transaction IDs that are directly connected to the transaction being reported.

(LCMSF206)

  1. What is the transaction category?

Select the transaction category for the IRPD transaction.

(LCMSF32)

  1. Is this transaction part of a RAS?

Always indicate False.

(LCMSF33)

  1. How many transactions are part of the RAS?

If the transaction is part of a RAS, indicate the applicable range for the number of the transactions in the same RAS that were current during the income year:

  • Low (1–5)
  • Moderate (6–50)
  • High (51 or more)

(LCMSF35)

  1. Australian counterparty name

Show the full name of the Australian counterparty (which may be the reporting entity itself) to this transaction/RAS.

(LCMSF207)

  1. ABN or TFN of the Australian counterparty to the transaction/RAS

Show the ABN or TFN of the Australian counterparty (which may be the reporting entity itself) to the transaction/RAS.

(LCMSF83 and LCMSF84)

  1. Name of the IRP non-resident counterparty to the transaction/RAS

Show the full name of the IRP non-resident counterparty to this transaction/RAS.

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)

  1. Tax residency of the IRP non-resident counterparty to the transaction/RAS

Show the country codeExternal Link for the country of tax residence of the IRP non-resident counterparty to this transaction/RAS.

(LCMSF38)

  1. 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/RAS 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)

  1. Country of permanent establishment of non-resident counterparty

This question applies only if you answer True to Question 10.

Show the country codeExternal Link of the PE.

(LCMSF209)

  1. 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/RAS during the income year, show this amount based on its accounting records.

If no amount of a capital nature was paid by the reporting entity in connection with this transaction/RAS during the income year, show zero.

(LCMSF39)

  1. 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/RAS during the income year, show this amount based on its accounting records.

If no amount of a capital nature was received by the reporting entity in connection with this transaction/RAS during the income year, show zero.

(LCMSF40)

  1. Was non-monetary consideration provided (of a capital nature for income tax purposes) for the transaction/RAS?

If non-monetary consideration of a capital nature was provided by the reporting entity in connection with this transaction/RAS during the income year, indicate True.

Otherwise indicate False.

(LCMSF85)

  1. Was non-monetary consideration obtained (of a capital nature for income tax purposes) for the transaction/RAS?

If non-monetary consideration of a capital nature was obtained by the reporting entity in connection with this transaction/RAS during the income year, indicate True.

Otherwise indicate False.

(LCMSF86)

  1. 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/RAS during the income year based on the reporting entity’s accounting records.

If there was no amount of expenditure that is not of a capital nature in connection with this transaction/RAS during the income year, show zero.

(LCMSF41)

  1. 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/RAS during the income year based on the reporting entity’s accounting records.

If there was no amount of revenue that is not of a capital nature in connection with this transaction/RAS during the income year, show zero.

(LCMSF42)

  1. Average balance of debt interests

Not applicable.

(LCMSF210)

  1. Capitalised interest deducted

Not applicable.

(LCMSF211)

  1. Average balance of debt interests

Not applicable.

(LCMSF212)

  1. Capitalised interest returned

Not applicable.

(LCMSF213)

  1. Book values

Not applicable.

(LCMSF214)

  1. Was non-monetary consideration provided (not of a capital nature for income tax purposes) for the transaction/RAS?

If non-monetary consideration not of a capital nature for income tax purposes was provided by the reporting entity in connection with this transaction/RAS during the income year, indicate True.

Otherwise indicate False.

(LCMSF44)

  1. Was non-monetary consideration obtained (not of a capital nature for income tax purposes) for the transaction/RAS?

If non-monetary consideration not of a capital nature was obtained by the reporting entity in connection with this transaction/RAS during the income year, indicate True.

Otherwise indicate False.

(LCMSF45)

  1. Did you enter into a deferred foreign currency payment arrangement in relation to this transaction

Not applicable.

(LCMSF215)

  1. Foreign Currency Reporting type

Not applicable.

(LCMSF216)

  1. Foreign Currency Code

This question applies only if you answer True to Question 25 and indicate that you entered into a Regular / short term foreign currency deferred payment arrangement at Question 26.

Show the Foreign Currency CodeExternal Link applicable to the foreign currency deferred payment arrangement.

(LCMSF217)

  1. Amount of foreign exchange losses deducted for the transaction/RAS

This question applies only if you answer False to Question 25.

Show the amount of foreign exchange losses deducted for income tax purposes by the reporting entity in connection with this transaction/RAS 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.

If there was no foreign exchange loss deducted for income tax purposes in connection with this transaction/RAS for the income year, show zero.

(LCMSF87)

  1. Foreign Currency Code

This question applies only if you answer False to Question 25.

Show the Foreign Currency CodeExternal Link in relation to foreign exchange losses deducted for the transaction/RAS

(LCMSF219)

  1. Amount of foreign exchange gains returned for the transaction/RAS

This question applies only if you answer False to Question 25.

Show the amount of foreign exchange gains assessable for income tax purposes in connection with this transaction/RAS 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.

If there was no foreign exchange gain assessable for income tax purposes in connection with this transaction/RAS, show zero.

(LCMSF43)

  1. Foreign Currency Code

This question applies only if you answer False to Question 25.

Show the Foreign Currency CodeExternal Link in relation to foreign exchange gains returned for the transaction/RAS

(LCMSF221)

  1. What transfer pricing / capital asset pricing methodology has been applied to this transaction/RAS?

If the reporting entity does not know which transfer pricing methodology has been applied to this transaction/RAS, select the code UNKT (Unknown TP Method).

If the reporting entity does not know which capital asset pricing methodology has been applied to this transaction/RAS, select the code UNKC (Unknown CAP Method).

(LCMSF46)

  1. 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 transaction/RAS for which the reporting entity has prepared relevant transfer pricing documentation, expressed as a percentage of total dollar value of this transaction/RAS.

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)

  1. 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 if the transaction category is not ordinary borrowings or ordinary loans.

(LCMSF88)

  1. 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 if the transaction category is not derivatives.

(LCMSF128)

  1. 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 if the transaction category is not derivatives.

(LCMSF129)

  1. If the reporting entity is an OBU, is this transaction/RAS an OB activity?

If the reporting entity is an OBU and this transaction/RAS is an OB activity under sections 121D and 121EAA of the ITAA 1936, indicate True.

Otherwise indicate False.

(LCMSF63)

  1. Is this transaction/RAS covered by a category on the exclusions list?

Always indicate false.

  1. What category of the exclusions list applies to this transaction/RAS?

Not applicable.

(LCMSF49)

  1. Transaction Comments

Provide any relevant comments in respect of the transaction/RAS.

(LCMSF222)

Reporting examples: IRPDs deferred currency payment arrangements

An example of an IRP deferred currency payment transaction can be found at Example 3. An example of completed questions for an IRP deferred currency payment can be found at Table 4 and Table 5

QC56216