IRPD debt interests (including ordinary loans and borrowings)

 

Table 33: IRPD debt interests (including ordinary loans and borrowings)

Code	Description of transaction category
OBL	Ordinary borrowings/loans (excluding trade financing) Any IRPDs in the nature of an ordinary borrowing or an ordinary loan, but excluding trade financing. ‘Borrowing’ and 'loan' should be given their ordinary meaning within the context of commercial and accounting practices. Ordinary borrowings/loans do not include raising finance by issue of, or assumption of, liabilities under: bonds promissory notes convertible notes shares other securities. Note: accounts payable and accounts receivable are not considered ordinary borrowings/loans unless they have been classified as debt interests. Accounts payable and accounts receivable should be reported as consideration paid or received for the IRPDs it relates to. Only report accounts payable or receivable as separate IRPDs when they have been reclassified as debt interests.
TFIN	Trade financing Any IRPDs in the nature of financing to fund trading liabilities including: issuing letters of credit (back-to-back, red-clause, revolving, stand-by, transferable) documentary credits documentary collections export credit.
BND	Bonds Any IRPDs in the nature of the issue, acquisition or holding of bonds including: corporate bonds sovereign bonds foreign currency bonds income bonds callable bonds zero coupon bonds.
PNOT	Promissory notes Any IRPDs in the nature of the issue, acquisition or holding of promissory notes. The term ‘promissory note’ has its ordinary meaning.
CNTDI	Convertible notes that are debt interests Any IRPDs in the nature of the issue, acquisition or holding of convertible notes that are debt interests under Division 974 of the ITAA 1997. The term ‘convertible note’ means promissory notes that may be converted into other debt or equity interests or securities upon specified contingent or non-contingent events.
CSTDI	Convertible shares that are debt interests Any IRPDs in the nature of the issue, acquisition or holding of convertible shares that are debt interests under Division 974 of the ITAA 1997. The term ‘convertible share’ means a share in a company of other equity interest that may be converted into other debt or equity interests or securities upon specified contingent or non-contingent events.
RPSDI	Redeemable preference shares that are debt interests Any IRPDs in the nature of the issue, acquisition or holding of redeemable preference shares that are debt interests under Division 974 of the ITAA 1997. The term ‘redeemable preference share’ means a share in a company that may be redeemed by the company or the holder upon specified contingent or non-contingent events under the terms or conditions of the share and which carries preferential rights as compared to other kinds of shares, such as a preferential right to a particular amount of distributions.
OKDI	Other kinds of debt interests Any IRPDs involving the issue, acquisition or holding of a debt interests under Division 974 of the ITAA 1997 but excluding the following transaction categories: ordinary borrowings/loans trade financing bonds promissory notes convertible notes that are debt interests convertible shares that are debt interests redeemable preference shares that are debt interests.

Special instructions for showing balances of borrowings, loans and other debt interests

For loans/borrowings, trade financing and other kinds of debt interests under Division 974 of the ITAA 1997, the average quarterly balance of the loan/borrowing or other debt interest during the income year is calculated in the same way as quarterly balances of borrowings and loans shown at Item 11a of the IDS.

More detail about how to calculate and show the average quarterly balance of loans, borrowings and other debt interests at Questions 7 and 8 of Part A of the local file is provided below.

1. Transaction Identifier

Show the Transaction ID for the transaction being reported.

(LCMSF31)

3. Related Transaction Identifier(s)

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

(LCMSF206)

4. What is the transaction category?

Select the transaction category for the IRPD transaction.

(LCMSF32)

5. Is this transaction part of a RAS?

If this transaction is covered by an IRPD agreement in a RAS, indicate True.

Otherwise indicate False.

(LCMSF33)

6. 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)

7. Australian counterparty name

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

(LCMSF207)

8. 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)

9. 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)

10. 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)

11. 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)

12. 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)

13. 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)

14. Amount of consideration received (of a capital nature for income tax purposes) for the transaction/RAS

(LCMSF40) Show the amount of consideration received of a capital nature for income tax purposes other than an amount relating to the loan balance.

15. 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)

16. 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)

17. Amount of expenditure (not of a capital nature for income tax purposes) for the transaction/RAS

The reporting rules for showing the amount of expenditure not of a capital nature for income tax purposes at this question depend on the nature of the IRP debt interests.

IRPD debt interests are ordinary borrowing or trade financing borrowing

Show the amount of interest paid and any other expenditure not of a capital nature for income tax purposes for the IRP ordinary borrowing or trade financing borrowing transaction/RAS during the income year based on the reporting entity’s accounting records, excluding interest that has been capitalised based on the reporting entity’s accounting records.

If there was no amount of interest paid or any other expenditure not of a capital nature for the IRP borrowing during the income year for the IRP ordinary borrowing or trade financing borrowing transaction/RAS during the income year, show zero.

IRPD debt interests are bonds / promissory notes / convertible notes that are debt interests / convertible shares that are debt interests / redeemable preference shares that are debt interests / other debt interests issued or assumed by reporting entity

Show the amount of interest paid, any other return paid or payable and any other expenditure not of a capital nature for income tax purposes for the IRP debt interest transaction/RAS for the income year based on the reporting entity’s accounting records, excluding interest that has been capitalised based on the reporting entity’s accounting records.

If there was no amount of interest paid, any other return paid or payable or any other expenditure not of a capital nature for the IRP debt interest transaction/RAS during the income year, show zero.

(LCMSF41)

18. Amount of revenue (not of a capital nature for income tax purposes) for the transaction/RAS

The reporting rules for showing the amount of revenue not of a capital nature for income tax purposes at this question depend on the nature of the IRP debt interests.

IRPD debt interests are ordinary loans or trade financing loans

Show the amount of interest received and any other revenue not of a capital nature for income tax purposes for the IRP ordinary loan or trade financing loan transaction/RAS during the income year based on the reporting entity’s accounting records, excluding interest that has been capitalised based on the reporting entity’s accounting records.

If there was no amount of interest received or any other revenue not of a capital nature for the IRP borrowing during the income year for the IRP ordinary loan or trade financing loan transaction/RAS during the income year, show zero.

IRPD debt interests are bonds / promissory notes / convertible notes that are debt interests / convertible shares that are debt interests / redeemable preference shares that are debt interests / Other debt interests held by reporting entity

Show the amount of interest received, any other return received or receivable and any other revenue not of a capital nature for income tax purposes for the IRP debt interest transaction/RAS for the income year based on the reporting entity’s accounting records, excluding interest that has been capitalised based on the reporting entity’s accounting records.

If there was no amount of interest received, any other return received or receivable or any other revenue not of a capital nature for the IRP debt interest transaction/RAS during the income year, show zero.

(LCMSF42)

19. Average balance of debt interests

Due to an ongoing issue resulting in the incorrect order of Question 19 and Question 21, we ask reporting entities to report IRPD borrowings and other inbound debt interests at this question for the 2020 reporting period, despite ‘debt interests held’ ordinarily meaning IRPD loans and other outbound debt interests.

*Note that this question will be changed to 'Average balance of debt interests issued (inbound borrowings)' in the local file / master file XML schema for reporting periods commencing on or after 1 January 2020.

The reporting rules for showing the average balance of IRP borrowings or other inbound IRP debt interests depends on the nature of the IRP debt interests.

Where IRPD debt interests are ordinary borrowings or trade financing borrowings

Show the amount of the average quarterly balance of the IRP ordinary borrowing transaction/RAS or for the IRP trade financing borrowing transaction/RAS during the income year determined by:

• adding up the amount of the balance of the borrowing based on the reporting entity’s accounting records at the start of the year and the amount of the balance of the borrowing based on the reporting entity’s accounting records at the end of each quarter
• dividing the result by five.

Where IRPD debt interests are bonds / promissory notes / convertible notes that are debt interests / convertible shares that are debt interests / redeemable preference shares that are debt interests / other debt interests issued or assumed by reporting entity

Show the amount of the average quarterly balance of the proceeds received for issue or assumption (price or value) of the bonds, notes or other debt interests for the IRP transaction/RAS during the income year determined by:

• adding up the amount of the price or value of the debt interest based on the reporting entity’s accounting records at the start of the year and the amount of the price or value of the debt interest based on the reporting entity’s accounting records at the end of each quarter
• dividing the result by five.

(LCMSF210)

20. Capitalised interest deducted

Show the amount of capitalised interest deducted in respect of the IRPD debt interest.

(LCMSF211)

21. Average balance of debt interests

Due to an ongoing issue resulting in the incorrect order of Question 19 and Question 21, we ask reporting entities to report IRPD loans and other outbound debt interests at this question for the 2020 reporting periods, despite ‘debt interests issued’ ordinarily meaning IRPD borrowings and other inbound debt interests.

* Note that this question will be changed to 'Average balance of debt interests held (outbound loans)' in the local file / master file XML schema for reporting periods commencing on or after 1 January 2020.

The reporting rules for showing the average balance of IRP loans or other outbound IRP debt interests depends on the nature of the IRP debt interests.

Where IRPD debt interests are ordinary loans or trade financing loans

Show the amount of the average quarterly balance for the IRP ordinary loan transaction/RAS or for the IRP trade financing loan transaction/RAS during the income year determined by:

• adding up the amount of the balance of the loans based on the reporting entity’s accounting records at the start of the year and the amount of the balance of the loans based on the reporting entity’s accounting records at the end of each quarter
• dividing the result by five.

Where IRPD debt interests are bonds / promissory notes / convertible notes that are debt interests / convertible shares that are debt interests / redeemable preference shares that are debt interests / other debt interests held by reporting entity

Show the amount of the average quarterly balance of the cost of acquisition (cost or value) for the bonds, notes or other debt interests for the IRP transaction/RAS during the income year determined by:

• adding up the amount of the cost or value of the debt interests based on the reporting entity’s accounting records at the start of the year and the amount of the cost or value of the debt interests based on the reporting entity’s accounting records at the end of each quarter
• dividing the result by five.

(LCMSF212)

22. Capitalised interest returned

Show the amount of capitalised interest returned in respect of the IRPD debt interest.

(LCMSF213)

23. Book values

Not applicable.

(LCMSF214)

24. 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)

25. 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 IRP transaction/RAS during the income year, indicate True.

Otherwise indicate False.

(LCMSF45)

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

Not applicable for this transaction category.

(LCMSF215)

27. Foreign Currency Reporting Type

Not applicable for this transaction category.

(LCMSF216)

28. Foreign Currency Code

Not applicable for this transaction category.

(LCMSF217)

29. 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)

30. Foreign Currency Code

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

(LCMSF219)

31. 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 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)

32. Foreign Currency Code

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

(LCMSF221)

33. 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)

34. 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%

If this transaction/RAS meets the conditions for the following Simplified Transfer Pricing Record Keeping (STPRK) options, show the code(s) for the STPRK option applied to the transaction/RAS:

7 = STPRK (Materiality)

13 = STPRK (Low Level Loans – Inbound)

14 = STPRK (Low Level Loans – Outbound)

16 = Green Zone (PCG 2017/4)

(LCMSF47)

35. If the reporting entity is a bank and this of transaction is in a RAS, has the special short-term tenor rule for ordinary borrowings and ordinary loans been applied to this RAS?

If the reporting entity has an unconditional or conditional Australian banking licence and has applied the special short term tenor rule for ordinary borrowings and ordinary loans, indicate True.

Otherwise indicate False.

(LCMSF88)

36. If the reporting entity is a bank and this of 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)

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?

Always indicate False if the transaction category is not derivatives.

(LCMSF129)

38. 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)

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

If this transaction/RAS is covered by the Simplified Transfer Pricing Record Keeping (Low Level Loans – Inbound) or the Simplified Transfer Pricing Record Keeping (Low Level Loans – Outbound) category on the exclusions list, indicate True.

Otherwise indicate False.

(LCMSF48)

40. What category of the Exclusions List applies to this transaction/RAS?

If the Simplified Transfer Pricing Record Keeping (Low Level Loans – Inbound) category on the exclusions list applies to this transaction/RAS and you have indicated True to Question 38, select the code STPRKLLI.

If the Simplified Transfer Pricing Record Keeping (Low Level Loans – Outbound) category on the exclusions list applies to this transaction/RAS and you have indicated True to Question 38, select the code STPRKLLO.

(LCMSF49)

1. Transaction Comments

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

(LCMSF222)

Reporting examples: IRPDs of a financial nature