Code |
Description of transaction category |
|---|---|
TPRN |
Tangible property of a revenue nature. Any IRPDs in tangible property of a revenue nature, including sale or purchase of trading stock and raw materials. The definition of trading stock in section 70-10 of the Income Tax Assessment Act 1997 (ITAA 1997) should be used to determine what trading stock is for the purpose of this question. |
Any amounts provided at any of the below questions should be reported in whole dollars and cents.
- 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.
(LCMSF206)
- What is the transaction category?
Select the transaction category for the IRPD transaction.
(LCMSF32)
- 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)
- 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)
- Australian counterparty name
Show the full name of the Australian counterparty (which may be the reporting entity itself) to this transaction/RAS.
(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/RAS.
(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/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)
- 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/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)
- Country of permanent establishment of non-resident counterparty
This question applies only if you answer True to Question 10.
Show the country code of the PE through which the non-resident counterparty entered into the transaction/RAS. 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/RAS 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/RAS 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/RAS 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/RAS 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/RAS 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/RAS 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/RAS during the income year 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/RAS 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/RAS during the income year 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)
Not applicable.
(LCMSF210)
- Capitalised interest deducted
Not applicable.
(LCMSF211)
- Average balance of debt interests held (Outbound Loans)
Not applicable.
(LCMSF212)
- Capitalised interest returned
Not applicable.
(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/RAS 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/RAS during the income year.
Otherwise indicate False.
(LCMSF45)
- Is the debt interest (including borrowing/loan) interest-free?
Not applicable
(LCMSF237)
- Did you enter into a deferred foreign currency payment arrangement in relation to this transaction?
Indicate True if you have entered into a foreign currency deferred payment arrangement in relation to this transaction.
Otherwise indicate False.
(LCMSF215)
- Foreign Currency Reporting type
This question applies only if you answered True to Question 26.
Indicate the type of foreign currency deferred payment arrangement entered into:
1 = short term foreign currency deferred payment arrangements
2 = longer term foreign currency deferred payment arrangements
If you have indicated 1, then you only need to provide the Foreign Currency CodeExternal Link at Question 28.
If you have indicated 2, then you need to provide the Foreign Currency CodeExternal Link at Question 28 and report the relevant associated IRPD foreign currency deferred payment arrangements transaction.
(LCMSF216)
- Foreign Currency Code
This question applies only if you answered True to Question 26 and indicated that you entered into a short term or longer term foreign currency deferred payment arrangement at Question 27.
Show the Foreign Currency CodeExternal Link applicable to the foreign currency deferred payment arrangement.
(LCMSF217)
- Amount of foreign exchange losses deducted for the transaction/RAS
Not applicable
(LCMSF87)
- Foreign Currency Code
Not applicable
(LCMSF219)
- Amount of foreign exchange gains returned for the transaction/RAS
Not applicable
(LCMSF43)
- Foreign Currency Code
Not applicable
(LCMSF221)
- What transfer pricing or 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 this transaction/RAS.
Select the code UNKC (Unknown CAP Method) if the reporting entity does not know which capital asset pricing methodology has been applied to this transaction/RAS.
(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 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 one of the following simplified transfer pricing record keeping (STPRK) options, outlined in PCG 2017/2 Simplified Transfer Pricing Record Keeping Options, show the codes for the STPRK option applied to the transaction/RAS:
(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 if the transaction category is not ordinary borrowings or ordinary loans.
(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 if the transaction category is not derivatives.
(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 if the transaction category is not derivatives.
(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/RAS 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?
If this transaction/RAS is covered by the following category on the exclusions list, indicate True.
Otherwise indicate False.
(LCMSF48)
- What category of the exclusions list applies to this transaction/RAS?
If you indicated True to Question 39, select the category on the exclusions list which applies to this transaction/RAS.
(LCMSF49)
- Transaction Comments
Provide any relevant comments in respect of the transaction/RAS.
(LCMSF222)
Reporting examples: IRPDs in tangible property of a revenue nature
Example 1: Sale of iron ore to Singapore IRP
Aus Co is a company that is resident in Australia for tax purposes.
Aus Co has an income tax year ending 30 June.
Aus Co’s functional currency for Australian tax purposes is Australian dollars.
During the income year Aus Co sold iron ore to its subsidiary in Singapore (Singapore Co) in more than 25 transactions under agreements on the same terms except for date, price, volume and delivery. The 25 transactions for the sale of iron ore are therefore in the same RAS in accordance with Appendix 8.
The aggregate sale price payable to Aus Co by Singapore Co for these sales was A$350 million as recorded in Aus Co’s accounting records.
Aus Co incurred expenditure of A$17 million for fees and commissions paid to Singapore Co for services provided to Aus Co in connection with sales and marketing of the iron ore.
Aus Co did not return foreign exchange gains or deduct foreign exchange losses during the income year for the sale of the iron ore because Aus Co had an Australian dollar functional currency for Australian tax purposes and the sale of the iron ore was for an Australian dollar sale price.
Aus Co did not enter into any deferred foreign currency payment arrangements.
Aus Co did not pay or obtain any consideration of a capital nature in relation to the sale of iron ore to Singapore Co.
Aus Co did not provide or obtain any non-monetary consideration in relation to the sale of iron ore to Singapore Co.
Aus Co shows the transaction category for the sale of iron ore to Singapore Co by using the transaction category ‘tangible property of a revenue nature’ which covers international related party dealings involving tangible property of a revenue nature, including sale or purchase of trading stock or raw materials.
Aus Co has applied the transfer pricing methodology ‘Comparable uncontrolled price method’ to this transaction/RAS.
Aus Co has prepared relevant contemporaneous transfer pricing documentation for 100% of this transaction/RAS.
The total amount returned in the income year by Aus Co in connection with the transaction/RAS is not less than A$2 million or less than 2% of Aus Co’s total IRPD revenue, so the transaction/RAS does not satisfy the category of ‘low value/low risk sale and purchase tangible trading stock agreements’ on the exclusions list.
Aus Co is not an OBU.
Singapore Co is a company that is resident in Singapore for tax purposes.
Singapore Co does not carry on its business operations through a permanent establishment.
The expenditure Aus Co incurred for fees and commissions paid to Singapore Co for services provided to Aus Co in connection with sale of the iron ore is expenditure for services provided by an IRP which will be shown for the relevant IRPD Services transaction. This is covered in Example 4
Aus Co completes the Questions for the transaction/RAS in this example 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 SAM transaction in Table 6 of Example 4] |
3 |
Transaction category |
TPRN |
4 |
Is this transaction part of a RAS? |
True |
5 |
How many transactions are part of the RAS? |
Moderate |
6 |
Australian counterparty name |
[Australian counterparty name] |
7 |
ABN or TFN of the Australian counterparty to the transaction/RAS |
[ABN or TFN] |
8 |
Name of the IRP non-resident counterparty to the transaction/RAS |
Singapore Co |
9 |
Tax residence of the IRP non-resident counterparty to the transaction/RAS |
SG |
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 |
350000000 |
18 |
Average balance of debt interests issued (Inbound Borrowings) |
Na |
19 |
Capitalised interest deducted |
Na |
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? |
Na |
26 |
Did you enter into a deferred foreign currency payment arrangement in relation to this transaction |
False |
27 |
Foreign Currency Reporting Type |
Na |
28 |
Foreign Currency Code |
Na |
29 |
Amount of foreign exchange losses deducted for the transaction/RAS |
Na |
30 |
Foreign Currency Code |
Na |
31 |
Amount of foreign exchange gains returned for the transaction/RAS |
Na |
32 |
Foreign Currency Code |
Na |
33 |
What transfer pricing/capital asset pricing methodology has been applied to the transaction/RAS? |
CUP |
34 |
What level of transfer pricing documentation has been prepared for this transaction/RAS? |
6 |
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
Example 2: Purchases of homewares from Irish IRP
Aus Co is a company that is resident in Australia for tax purposes.
Aus Co has an income tax year ending 30 June.
Aus Co’s functional currency for Australian tax purposes is Australian dollars.
During the income year Aus Co purchases a range of homeware and kitchen goods from an Irish subsidiary (Ireland Co) of its ultimate UK parent company, involving eight separate shipments of goods, under the terms of an umbrella procurement agreement and associated specific agreement documentation with Ireland Co.
The eight shipments were of the same kinds of goods and the purchase of the goods were on the same terms except for date, volume, price and delivery. The purchase of the goods in the eight shipments from the same IRP were therefore in the same RAS in accordance with Appendix 8.
The aggregate purchase price payable by Aus Co to Ireland Co for these sales was US$12 million as recorded in Aus Co’s accounting records. The Australian dollar equivalent of the total of the US dollar purchase price on the date of billing was $15 million as recorded in Aus Co’s accounting records.
Under the terms of the procurement and sale agreements with Ireland Co, the purchase price payable by Aus Co was due for payment by Aus Co 60 days after billing. For all shipments Aus Co satisfied payment of the purchase price in accordance with the terms of the procurement and sale agreements within 100 days of the date of billing.
Aus Co returned assessable foreign exchange gains of $200,000 and deducted foreign exchange losses of $150,000 under Subdivision 775-B of the ITAA 1997 during the income year for foreign exchange gains and foreign exchange losses made as a result of fluctuations in the AUD/USD exchange rate between the date of billing and the date of payment by Aus Co for the purchase of the homeware goods.
Aus Co did not have any revenue or any other expenditure as recorded in Aus Co’s accounting records for the purchase of the homeware goods from Ireland Co.
Aus Co did not provide or obtain any consideration of a capital nature in relation to the purchase of the homeware goods from Ireland Co.
Aus Co did not provide or obtain any non-monetary consideration in relation to the purchase of the homeware goods from Ireland Co.
Aus Co shows the transaction category for the purchase of the homeware goods from Ireland Co by using the transaction category ‘tangible property of a revenue nature', which covers international related party dealings involving tangible property of a revenue nature, including sale or purchase of trading stock or raw materials.
Aus Co has applied the transfer pricing methodology ‘Comparable uncontrolled price method’ to this transaction/RAS.
Aus Co has prepared relevant contemporaneous transfer pricing documentation for 100% of this transaction/RAS.
The total amount deducted in the income year by Aus Co in connection with this tangible goods transaction/RAS is less than A$2 million or less than 2% of Aus Co’s total IRPD expenditure.
The homeware and kitchen goods were not purchased from Ireland Co in connection with:
- the use or enjoyment of any trademark, patent, design, copyright, other intellectual property, secret formula or process or similar property or rights, or
- any other IRP agreement.
The agreements in the RAS under which Aus Co purchases the homeware and kitchen goods from Ireland Co solely cover:
- the sale or purchase of the homeware and kitchen goods
- rights and obligations in connection with effecting the purchase of the homeware and kitchen goods.
This tangible goods transaction/RAS therefore satisfies the category of ‘Low value/low risk sale and purchase tangible trading stock agreements’ on the exclusions list.
Aus Co is not an OBU.
Ireland Co is a company that is resident in Ireland for tax purposes.
Ireland Co does not carry on its business operations through a permanent establishment.
Aus Co completes the Questions for the transaction/RAS in this example 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] |
3 |
Transaction category |
TPRN |
4 |
Is this transaction part of a RAS? |
True |
5 |
How many transactions are part of the RAS? |
Moderate |
6 |
Australian counterparty name |
[Australian counterparty name] |
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 |
15000000 |
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) |
Na |
19 |
Capitalised interest deducted |
Na |
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? |
Na |
26 |
Did you enter into a deferred foreign currency payment arrangement in relation to this transaction |
True |
27 |
Foreign Currency Reporting Type |
1 |
28 |
Foreign Currency Code |
USD |
29 |
Amount of foreign exchange losses deducted for the transaction/RAS |
Na |
30 |
Foreign Currency Code |
Na |
31 |
Amount of foreign exchange gains returned for the transaction/RAS |
Na |
32 |
Foreign Currency Code |
Na |
33 |
What transfer pricing/capital asset pricing methodology has been applied to the transaction/RAS? |
CUP |
34 |
What level of transfer pricing documentation has been prepared for this transaction/RAS? |
6 |
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? |
True |
40 |
What category of the Exclusions List applies to this transaction/RAS? |
LVLRSA |
41 |
Transaction Comments |
[Comments] |
End of example
Example 3: Purchase of homeware goods from Irish IRP giving rise to longer term foreign currency deferred payment arrangements
The facts are the same facts as Example 2, except for the following:
- Aus Co failed to satisfy its payment obligations to Ireland Co for the US dollar purchase price of the shipments under the sale and purchase agreements.
- Aus Co's unsatisfied payment obligations remained outstanding more than 12 months after they were due under the sale and purchase agreements. The agreements for purchase of tangible goods from Ireland Co therefore gave rise to longer term foreign currency deferred payment arrangements.
- Aus Co could have avoided longer term foreign currency deferred payment arrangements if Aus Co had satisfied the amounts payable to Ireland Co less than 12 months after they were due, including through an intercompany loan from an IRP which would need to be separately reported as an IRPD Debt Interests transaction.
In accordance with the instructions for IRPDs in Tangible property of a revenue nature, Aus Co completes the Questions for the purchase of goods transaction/RAS based on its accounting records, as shown in the following table.
In accordance with the instructions for IRPD foreign currency deferred payments arrangements, Aus Co will also need to complete the Questions for the longer term foreign currency deferred payment arrangements transaction as shown in Table 60 of Example 17.
Question no. |
Question label |
Response |
|---|---|---|
1 |
Transaction Identifier |
[Transaction ID] |
2 |
Related Transaction Identifier(s) |
[Transaction IDs for FCDPTTS transaction in Table 60 of Example 17] |
3 |
Transaction category |
TPRN |
4 |
Is this transaction part of a RAS? |
True |
5 |
How many transactions are part of the RAS? |
Moderate |
6 |
Australian counterparty name |
[Australian counterparty name] |
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 |
15000000 |
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) |
Na |
19 |
Capitalised interest deducted |
Na |
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? |
Na |
26 |
Did you enter into a deferred foreign currency payment arrangement in relation to this transaction |
True |
27 |
Foreign Currency Reporting Type |
2 |
28 |
Foreign Currency Code |
USD |
29 |
Amount of foreign exchange losses deducted for the transaction/RAS |
Na |
30 |
Foreign Currency Code |
Na |
31 |
Amount of foreign exchange gains returned for the transaction/RAS |
Na |
32 |
Foreign Currency Code |
Na |
33 |
What transfer pricing/capital asset pricing methodology has been applied to the transaction/RAS? |
CUP |
34 |
What level of transfer pricing documentation has been prepared for this transaction/RAS? |
6 |
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? |
True |
40 |
What category of the Exclusions List applies to this transaction/RAS? |
LVLRSA |
41 |
Transaction Comments |
[Comments] |
End of example