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Appendices

Last updated 4 July 2023

Appendix 1: Transaction categories

Table 62: IRPDs in tangible property of a revenue nature

Code

Value

TPRN

Tangible property of a revenue nature

Table 63: IRPD service arrangements

Code

Value

TRS

Treasury-related services

MAS

Management and administration services

INSERV

Insurance services

REINSERV

Reinsurance services

RD

Research and development services

SAM

Sales and marketing services

SITS

Software and IT services

TS

Technical services

LS

Logistics services

AM

Asset management services

OS

Other services

Table 64: IRPD use rights

Code

Value

RUIP

Rights to use IP

ORSR

Other rights to use, supply or receive where consideration is royalty under section 6(1) of the ITAA 1936

LF

Licence fees

RRP

Rent of real property

HLPE

Hire or lease of plant or equipment

LHORP

Lease or hire of other property or rights

Table 65: IRPD share-based employment remuneration

Code

Value

SBER

Share based employment remuneration

Table 66: Other revenue (non-financial) IRPDs

Code

Value

CCA

Cost contribution arrangement

ORIRPD

Other revenue IRPDs

Table 67: IRPD derivative transactions

Code

Value

CCIRS

Cross currency interest rate swap

CDCSFFO

Currency derivative (not cross currency interest rate swap), including currency swap, forward, future or option

FFIRS

Fixed for floating interest rate swap (not cross currency)

OIRD

Other interest rate derivative (not cross currency)

CDS

Credit default swap

AS

Asset swap

CDCS

Commodity derivative, including commodity swap, forward, future or option

OD

Other derivative

Table 68: IRPD debt interests (including ordinary loans and borrowings)

Code

Value

OBL

Ordinary borrowings/loans (excluding trade financing)

TFIN

Trade financing

BND

Bonds

PNOT

Promissory notes

CNTDI

Convertible notes that are debt Interests

CSTDI

Convertible shares that are debt Interests

RPSDI

Redeemable preference shares that are debt Interests

OKDI

Other kinds of debt Interests

Table 69: IRPD debt factoring or debt securitisation

Code

Value

IDF

Inward debt factoring

ODF

Outward debt factoring

IDSEC

Inward debt securitisation

ODSEC

Outward debt securitisation

Table 70: Other kinds of IRPDs of a financial nature

Code

Value

GILDI

Guarantee or indemnity of liability under debt Interest

GIOKL

Guarantee or indemnity of other kind of liability

IN

Insurance

REIN

Reinsurance

OFD

Other financial dealings

Table 71: IRPDs involving disposal or acquisition of tangible property of a non-revenue (capital) nature

Code

Value

RPRT

Real property

PLEQ

Plant or equipment

OTPRTY

Other tangible property

Table 72: IRPDs involving disposal or acquisition of intangible property or rights of a non-revenue (capital) nature

Code

Value

ASIP

Assignment of IP

IOSH

Issue of ordinary shares

AOSH

Assignment of ordinary shares

IEIOOS

Issue of equity interest other than ordinary shares

AQIOS

Assignment of equity interest other than ordinary Shares

ASSD

Assignment of debts

ASSL

Assignment of liabilities

ASSBC

Assignment of benefit of contracts (excluding assignment of equity interests, debts or IP)

ASSOPR

Assignment of other intangible property or rights

Table 73: IRPD Foreign currency deferred payment arrangements

Code

Value

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

FCDRUIP

Foreign currency deferred payment arrangement for rights to use IP provided to IRP

FCDRUIPI

Foreign currency deferred payment arrangement for rights to use IP obtained from IRP

FCDORSR

Foreign currency deferred payment arrangement for other royalty from IRP for rights or services provided to IRP

FCDORSRI

Foreign currency deferred payment arrangement for other royalty to IRP for rights or services obtained from IRP

FCDLF

Foreign currency deferred payment arrangement for non-royalty type licence provided to IRP

FCDLFI

Foreign currency deferred payment arrangement for non-royalty type licence obtained from IRP

FCDLHORP

Foreign currency deferred payment arrangement for lease or hire of property or rights to IRP other than real property or plant or equipment

FCDLHORPI

Foreign currency deferred payment arrangement for lease or hire of property or rights from IRP other than real property or plant or equipment

Appendix 2: Exclusions list

Table 74: Exclusions list

Code

Exclusions list

STPRKTS

Simplified Transfer Pricing Record Keeping (Technical Services)

STPRKLLI

Simplified Transfer Pricing Record Keeping (Low Level Loans – Inbound)

STPRKLLO

Simplified Transfer Pricing Record Keeping (Low Level Loans – Outbound)

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

STPRKLVS

Simplified Transfer Pricing Record Keeping (Low Value Adding Intra-Group Services)

Appendix 3: TP methods/CAP methods

Table 75: TP methods/CAP methods

Code

Value

APPC

Apportionment of costs

APPI

Apportionment of Income

CUP

Comparable uncontrolled price method

CCA

Cost-contribution arrangement

CP

Cost-plus method

FMUAC

Fixed mark-up applied to cost

FPRP

Fixed percentage of resale price

MC

Marginal costing

PS

Profit split method

RPM

Resale price method

TNM

Transactional net margin method

TNMW

Transactional net margin method (whole-of-entity)

OTH

Other arm's length methods

NON

None

UNKT

Unknown (transfer pricing method)

CPR

Cost Price

DVAL

Directors valuation

DCF

Discounted cash flow

IVAL

Independent valuation

NCON

Nil consideration

QMRP

Quoted market price

WDVAL

Written-down value

OM

Other methods

UNKC

Unknown (capital asset pricing method)

Appendix 4: TP documentation codes/STPRK options

Table 76: TP documentation codes/STPRK options

Code

Value

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%

7

Simplified transfer pricing record keeping (materiality)

8

Simplified transfer pricing record keeping (small business)

9

Simplified transfer pricing record keeping (distributors)

10

Simplified transfer pricing record keeping (low value adding intra-group services)

12

Simplified transfer pricing record keeping (technical services)

13

Simplified transfer pricing record keeping (low level loans – inbound)

14

Simplified transfer pricing record keeping (low level loans – outbound)

15

Green Zone (PCG 2017/1)

16

Green Zone (PCG 2017/4)

Appendix 5: Accounting records/income tax records

Table 77: 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

CSCSFFO

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

FCDSTTS

Foreign currency deferred payment arrangement for sale of Tangible Trading Stock

Accounting records

FCDPTTS

Foreign currency deferred payment arrangement for purchase of Tangible Trading Stock

Accounting records

FCDAPS

Foreign currency deferred payment arrangement for provision of Services

Accounting records

FCDAAS

Foreign currency deferred payment arrangement for acquisition of Services

Accounting records

FCDRRP

Foreign currency deferred payment arrangement for rent of real property to IRP

Accounting records

FCDRRPI

Foreign currency deferred payment arrangement for rent of real property from IRP

Accounting records

FCDHLP

Foreign currency deferred payment arrangement for hire or lease of plant or equipment to IRP

Accounting records

FCDHLPE

Foreign currency deferred payment arrangement for hire or lease of plant or equipment from IRP

Accounting records

FCDSBER

Foreign currency deferred payment arrangement for share based employment recharge to IRP

Accounting records

FCDSBERI

Foreign currency deferred payment arrangement for share based employment recharge from IRP

Accounting records

FCDRUIP

Foreign currency deferred payment arrangement for rights to use IP provided to IRP

Accounting records

FCDRUIPI

Foreign currency deferred payment arrangement for rights to use IP obtained from IRP

Accounting records

FCDORSR

Foreign currency deferred payment arrangement for other royalty from IRP for rights or services provided to IRP

Accounting records

FCDORSRI

Foreign currency deferred payment arrangement for other royalty to IRP for rights or services obtained from IRP

Accounting records

FCDLF

Foreign currency deferred payment arrangement for non-royalty type licence provided to IRP

Accounting records

FCDLFI

Foreign currency deferred payment arrangement for non-royalty type licence obtained from IRP

Accounting records

FCDLHORP

Foreign currency deferred payment arrangement for lease or hire of property or rights to IRP other than real property or plant or equipment

Accounting records

FCDLHORPI

Foreign currency deferred payment arrangement for lease or hire of property or rights from IRP other than real property or plant or equipment

Accounting records

Appendix 6: Assessable foreign exchange gains and deductible foreign exchange losses for Australian income tax

  1. Subject to any applicable special reporting rules in Appendix 7, 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 and the relevant foreign currency at Questions 29 to 32 in Part A of the local file for the relevant IRP transaction/RAS.
  2. 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.
  3. Examples include:

    1. 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
    2. 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.
  4. Note: the payment obligation under the underlying IRPD transaction, such as the purchase of goods or services, will cease to be in existence if it is satisfied, including through an intercompany loan with an IRP (which would need to be separately reported as an IRPD Debt Interests transaction). Refer to Appendix 7 about foreign currency deferred payment arrangements.
  5. 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.
  6. For more guidance on entities covered by TOFA and the operation of TOFA, refer to Guide to the taxation of financial arrangements (TOFA).
  7. 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.
  8. 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.
  9. 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.
  10. Under Subdivision 775-B of the ITAA 1997 there are five main types of Forex realisation events:
    1. event 1 happens if you dispose of foreign currency, or a right to receive foreign currency, to another entity
    2. 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)
    3. event 3 happens if you cease to have an obligation to receive foreign currency
    4. event 4 happens if you cease to have an obligation to pay foreign currency
    5. event 5 happens if you cease to have a right to pay foreign currency.
  11. There are also special rules:
    1. under Subdivision 775-C of the ITAA 1997, for rollover for facility agreements and special rules for securities issued under the facility agreements
    2. 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
    3. 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 7: Special rules for reporting foreign exchange gains and losses in Local File – Part A

  1. For reporting entities that have made an election under Subdivision 960–D of the Income Tax Assessment Act 1997 (ITAA 1997) to adopt a functional currency for Australian tax purpose that is not Australian dollars, the reference to ‘foreign currency’ in these instructions may include Australian dollars.
  2. Reporting FX gains and losses calculated using the financial reports method under TOFA

  3. In the case of reporting entities that have elected the ‘financial reports’ method for their relevant IRPD financial arrangements under Subdivision 230-F of the ITAA 1997, for IRP financial arrangements where the FX gains and losses have been calculated using the financial reports method in Subdivision 230-F, there is no requirement to separately report any portion of the annual Division 230 gain or loss attributable to realised or unrealised FX gains/losses in Part A of the local file for the relevant transaction/RAS. The whole amount of the fair value movements or annual adjustments using the financial reports method under Division 230 (including any portion attributable to realised or unrealised FX gains/losses) is required to be reported for the relevant transaction/RAS as either:
    • ‘Expenditure’ (of a non-capital nature) at Question 16 (LCMSF41)
    • ‘Revenue’ (of a non-capital nature) at Question 17 (LCMSF42).

    For the 2023 reporting period, report a zero value for the transaction/RAS at:

    • Question 29 (LCMSF87) for FX losses deducted
    • Question 31 (LCMSF43) for FX gains returned.

    Reporting FX gain and losses for financial institutions

  4. As an interim measure pending finalisation of permanent reporting rules for financial institutions, the special interim rules developed for the 2018 reporting of financial institutions will remain for the 2023 reporting year.
  5. FX gains and losses for transactions on capital account (financial institutions)

  6. FX gains and losses for transactions on capital account for income tax purposes must be reported for the particular transaction/RAS you show at Part A as outlined in the specific local file instructions.
  7. Where your accounting systems do not produce the amounts of the FX gains and losses for tax purposes for the particular transaction/RAS you show at Part A, you must make best efforts to determine and report the FX gains returned and the FX losses deducted for the transaction/RAS based on the values for the relevant foreign currency denominated liabilities or receivables in your accounting systems.
  8. FX gains and losses for transactions on revenue account (financial institutions)

  9. For FX gains and losses associated with transactions that are on revenue account for income tax purposes, the following approach can be taken:
    • If your current accounting system outputs include the relevant FX gains and losses for the transaction/RAS as outlined in the local file instructions, show these for the transaction/RAS.
    • If your current accounting system outputs only include the relevant FX gains and losses on an aggregated basis, make a best effort to report the FX gains or losses on an aggregated basis (including the Foreign Currency CodeExternal Link for the most substantive currency), per transaction type/RAS. This same aggregated amount would be reported at the labels for FX losses deducted (LCMSF87) or FX gains returned (LCMSF43) for every transaction/RAS included in calculating the aggregated FX gain or loss amount.
    • If your current accounting system outputs only include the relevant FX gains and losses on an aggregated basis and you cannot reasonably determine or estimate the aggregated amount of the FX gains or losses per transaction type, show the aggregated amount of the FX gains or losses for all the relevant transaction types of a revenue nature (including the Foreign Currency CodeExternal Link for the most substantive currency). This aggregated amount would be reported at the labels for FX losses deducted (LCMSF87) or FX gains returned (LCMSF43) for every transaction/RAS included in calculating the aggregated FX gain or loss amount.

    Reporting FX gains and losses for deferred foreign currency payment arrangements for certain qualifying transaction categories

  10. A special reporting rule applies to IRPDs involving deferred foreign currency payment arrangements for the following kinds of local file Transaction categories:
  11. What are foreign currency deferred payment arrangements (FCDPA)?

  12. A foreign currency deferred payment arrangement arises where foreign currency amounts payable under an IRPD transaction (underlying IPRD transaction) are:
    • not paid on the date they are due and owing under the underlying IRPD transaction, and
    • are deferred and remain outstanding and unsatisfied under the underlying IRPD transaction.
  13. A FCDPA transaction would therefore no longer be in existence if all of the foreign currency amounts payable under the underlying IRPD transaction had been satisfied, including through an intercompany loan with an IRP (which would need to be separately reported as a IRPD Debt Interests transaction).
  14. Short term deferred foreign currency payment arrangements

    • If the foreign currency deferred payment arrangements for the eligible IRP transaction/RAS do not involve payment or other satisfaction of the amounts payable under the arrangements more than 12 months after the date the amounts become due, then the following codes are shown for the relevant underlying IRP transaction/RAS:
    • code 1 indicating short term foreign currency deferred payment arrangements at Question 27 (LCMSF216), and
    • code indicating the relevant foreign currency at Question 28 (LCMSF217).
  15. There is no requirement to show the amount of FX gains returned or FX losses deducted for the relevant IRP transaction/RAS in Part A of the Local File.
  16. Longer term deferred foreign currency payment arrangements

  17. If the foreign currency deferred payment arrangements for the eligible IRP transaction/RAS involve payment or other satisfaction of the relevant amounts payable under the arrangements more than 12 months after the date the amounts become due then the following codes are shown for the relevant underlying IRP transaction/RAS which gives rise to the foreign currency deferred payment arrangement:
    • code 2 indicating longer term foreign currency deferred payment arrangements at Question 27 (LCMSF216), and
    • code indicating the relevant foreign currency at Question 28 (LCMSF217).
  18. The longer term foreign currency deferred payment arrangement is then separately reported at whichever of the following Transaction Categories are applicable:
    • Foreign currency deferred payment arrangement for sale of Tangible Trading Stock (FCDSTTS)
    • Foreign currency deferred payment arrangement for purchase of Tangible Trading Stock (FCDPTTS)
    • Foreign currency deferred payment arrangement for provision of Services (FCDAPS)
    • Foreign currency deferred payment arrangement for acquisition of Services (FCDAAS)
    • Foreign currency deferred payment arrangement for rent of real property to IRP (FCDRRP)
    • Foreign currency deferred payment arrangement for rent of real property from IRP (FCDRRPI)
    • Foreign currency deferred payment arrangement for hire or lease of plant or equipment to IRP (FCDHLP)
    • Foreign currency deferred payment arrangement for hire or lease of plant or equipment from IRP (FCDHLPE)
    • Foreign currency deferred payment arrangement for share based employment recharge to IRP (FCDSBER)
    • Foreign currency deferred payment arrangement for share based employment recharge from IRP (FCDSBERI)
    • Foreign currency deferred payment arrangement for rights to use IP provided to IRP (FCDRUIP)
    • Foreign currency deferred payment arrangement for rights to use IP obtained from IRP (FCDRUIPI)
    • Foreign currency deferred payment arrangement for other royalty from IRP for rights or services provided to IRP (FCDORSR)
    • Foreign currency deferred payment arrangement for other royalty to IRP for rights or services obtained from IRP (FCDORSRI)
    • Foreign currency deferred payment arrangement for non-royalty type licence provided to IRP (FCDLF)
    • Foreign currency deferred payment arrangement for non-royalty type licence obtained from IRP (FCDLFI)
    • Foreign currency deferred payment arrangement for lease or hire of property or rights other than real property or plant or equipment to IRP (FCDLHORP)
    • Foreign currency deferred payment arrangement for lease or hire of property or rights other than real property or plant or equipment from IRP (FCDLHORPI)

    General rules for reporting FX gains and losses (covering all other scenarios)

  19. For any IRP transaction/RAS in the following transaction category or Transaction category groupings:
  20. The following is shown for the relevant IRP transaction/RAS:
    • the amount of any FX gains returned and FX losses deducted for the IRP transaction/RAS for Australian income tax
    • code indicating the relevant foreign currency.

Appendix 8: Guidance on providing international related party agreements

  1. This appendix provides guidance on the provision of International Related Party (IRP) agreements as part of Part B of the local file for country-by-country (CBC) reporting. The rules in this guidance seek to balance the function of the local file and the compliance costs associated with providing agreement documentation in Part B of the local file.
  2. Copies of IRP agreements generally need to be provided in Part B for the transactions shown at Part A of the local file which are not covered by the exclusions list.
  3. A key design feature of the local file is the requirement to show values in Part A and provide agreements in Part B for individual transactions unless the transaction is covered by one of the eight categories on the exclusions list. This transaction level reporting design feature is expected to significantly improve the ATO’s ability to undertake high level risk assessment of profit shifting through related party transactions.
  4. The rules in this guidance seek to balance the function of the local file and the compliance costs associated with providing agreement documentation in Part B of the local file. Accordingly, the ATO will not require all of the agreement documentation for transactions shown at Part A for agreements included in a Relevant Agreement Series (RAS).
  5. The rules have been developed to reduce compliance costs while not inadvertently creating opportunities for non-disclosure of potentially significant profit shifting risks through aggregating transactions. For example, the RAS rules are designed so that certain kinds of transactions or agreements cannot be aggregated, in particular:
    1. financing transactions involving different currencies or different express tenors or duration cannot be aggregated, except to the extent permitted under the special rules for banks
    2. derivative, guarantee/indemnity or insurance/reinsurance transactions that hedge, guarantee or insure specific exposures, liabilities or risks which arise in connection with the reporting entity’s related party dealings cannot be aggregated with agreements for other derivatives, guarantees/indemnities or insurance/reinsurance
    3. for reporting entities that are an offshore banking unit (OBU), agreements for transactions which are OB activities (taxable or deductible at the special concessional income tax rate of 10%) cannot be aggregated with agreements for transactions which are non-OB activities (taxable or deductible at the normal corporate income tax rate, currently 30%)
    4. transactions on capital account (i.e., not on revenue account).

    Outlined below are:

    General principles on providing IRP agreements

    Written agreement is provided in connection with information provided in Part A for relevant IRP transaction

  6. The local file has been designed so that, unless a transaction is on the exclusions list, the values shown in Part A of the local file for a particular transaction are linked with either:
    1. an agreement provided in Part B or an identified agreement previously provided to the ATO
    2. an indication by the reporting entity in Part B that either:
      1. there is no written agreement documentation covering the transaction shown at Part A
      2. the reporting entity is not able to obtain from any of the related counterparties the written agreement documentation covering the transaction shown at Part A.
  7. If a single written agreement covers more than one kind of transaction category then:
    1. the information required in Part B will need to be provided for each kind of transaction category covered by the agreement
    2. each of the transactions shown in Part A will need to be linked to the written agreement provided in Question 6 (LCMSF224) of Part B of the local file by providing the Transaction IDs for the other IRPD transactions/RAS covered by the written agreement.   

    Information to enable identification is needed where written agreements have already been provided to the ATO

  8. Agreements (including amendment agreements) for transactions shown at Part A that have already been provided to the ATO do not need to be provided again. However, the following information must be provided in Part B to ensure the ATO can identify the correct agreement:
    1. the title of the written agreement or amendment agreement
    2. the year in which the agreement or amendment agreement was provided to the ATO
    3. whether the previously provided written agreement or amendment agreement was part of your local file lodgment for a previous reporting period. 
  9. If the agreements that have already been provided to the ATO have subsequently been amended and the amendment agreements have not been provided to the ATO, the amendment agreements or the original agreement incorporating the amendments need to be provided at Part B.
  10. No requirement to create written agreement but must indicate in Part B if no written agreement exists

  11. Reporting entities are not required to create written agreement documentation solely for the purposes of Part B of the local file. However, if there is no written agreement documentation, the reporting entity must indicate that there is no written agreement in Part B.
  12. Must indicate if written agreement cannot be obtained by Reporting Entity from related overseas counterparty

  13. If there is written agreement documentation but the reporting entity is not able to obtain this from the related overseas counterparty, the reporting entity is required to indicate this in Part B.
  14. What comprises written agreements in various scenarios?

  15. It is expected it will often be the case that all the terms of an international related party dealing (IRPD) will be evidenced in a single executed written agreement between a Reporting Entity and its overseas related parties. In this common scenario, the executed written agreement should be provided in Part B.
  16. However, if the terms of an IRPD have been amended by written agreement before or during the income year, the executed amendment agreement(s) or the original agreement incorporating the amendments should also be provided in Part B.
  17. Where an agreement contemplates that specific terms will be agreed between the parties in another agreement(s), the agreement documentation for the transaction must include the other written agreement(s). For example:        
    1. a written ‘Confirmation’ agreeing the terms of a derivative will be provided together with the International Swaps and Derivatives Association (ISDA) master agreement or other agreement setting out the general terms agreed to apply for any derivative that is contracted between the parties
    2. written agreements for the supply of services, goods or other property ordered or supplied in accordance with an overarching agreement setting out general terms or processes for the supply will be provided together with the overarching agreement.

    Example

    Foreign Co and its subsidiary, Australia Co, have entered into an overarching agreement for Australia Co to sell aluminium and aluminium alloys to Foreign Co. The agreement provides that Australia Co will sell the aluminium as ordered by Foreign Co in accordance with the terms of the overarching agreement. During the income year, in accordance with the relevant terms of the agreement, Foreign Co orders 1,000 tonnes of aluminium and Australia Co and Foreign Co enter into specific written agreements in relation to this sale.

    In Part A of the local file, Australia Co shows the required information for the sale of aluminium to Foreign Co using the transaction category ‘Tangible property of a revenue nature’.

    In Part B of the local file, Australia Co provides, in connection with this transaction, the overarching agreement and the specific agreements for the sale by Australia Co to Foreign Co.

    End of example
  18. Where there is no agreement documentation for the transaction shown at Part A, but the reporting entity has other documents which record the terms of the agreement, the reporting entity has the option of providing these other documents in Part B.
  19. If this scenario applies and the reporting entity chooses to use this option, the reporting entity will:        
    1. indicate in Part B there is no written agreement documentation covering the transaction shown at Part A
    2. provide the other documents recording the terms of the agreement.    

    Example

    During the income year Foreign Co lends Australian dollars to its subsidiary, Australia Co. There is no agreement documentation for the loan between Foreign Co and Australia Co. However, Australia Co has an email record in its systems that outlines the terms of the loan provided by Foreign Co, being A$100 million for a term of one year at a fixed rate of 3%.

    In Part A of the local file, Australia Co shows the required information for the borrowing under the loan from Foreign Co using the transaction category ‘Ordinary borrowings’.

    In Part B of the local file, Australia Co may choose to provide in connection with the transaction the email record in Australia Co’s systems of the terms of loan from Foreign Co.

    If Australia Co chooses to provide this record of the terms of the loan in its systems, Australia Co will:

    • indicate in Part B there is no written agreement documentation covering the loan transaction shown at Part A
    • provide the email record in its systems of the terms of the loan in Part B.

    If Australia Co does not choose to provide this record of the terms of the loan in its systems, Australia Co will indicate in Part B there is no written agreement documentation covering the loan transaction shown at Part A.

    End of example

    Relevant Agreement Series

  20. A Relevant Agreement Series (RAS) is a repeating series of transactions or dealings on revenue account between the reporting entity and the same IRP entity on the same terms except only for date, volume, price and delivery.
  21. For these kinds of transactions, an additional condition needs to be satisfied:  
    1. derivatives
    2. guarantees or indemnities
    3. insurance or reinsurance.

    In these cases, refer to RAS Condition 4.

  22. Where an IRPD transaction or agreement forms part of a RAS:  
    1. in Part A, the dollar values for each kind of transaction category covered by the RAS are aggregated
    2. the criteria in the Exclusions List are applied on the basis of the aggregated amounts
    3. in Part B, written agreement documentation only needs to be provided for a material representative agreement in the RAS that was current during the income year.    

    What qualifies as a RAS?

  23. For a transaction or agreement series to qualify as a RAS, these four conditions must be met:  
    1. transaction or agreements must be with the same IRP
    2. transaction or agreements must be on the same terms except for date, volume, price and delivery
    3. the transactions must be on revenue account (i.e., are not on capital account)
    4. derivative, guarantee/indemnity or insurance/reinsurance transactions or agreements hedging, guaranteeing or insuring specific exposures, liabilities or risks arising in connection with the reporting entity’s related party dealings cannot be included in the same RAS as other derivative, guarantee/indemnity or insurance/reinsurance agreements.      
  24. The principles for determining a material and representative agreement of a RAS are outlined below at paragraphs 39–40.
  25. There are also special rules if the reporting entity is an OBU or a bank:        
    1. the special rules for OBUs with respect to OB and non-OB activities are outlined below at paragraph 46
    2. the special rules for Condition 2 with respect to ordinary borrowings and loans, qualifying short term derivatives and qualifying FX derivatives of banks are outlined below at paragraphs 47–58.    

    RAS Condition 1 – agreements are with the same IRP

  26. The RAS will only include transaction or agreements between the same parties.
  27. Where the IRP transaction or agreement is between more than two parties, this condition means that all of the parties to the transaction or agreement must be the parties to all the other transaction or agreements in order for the transaction or agreements to qualify as a RAS.
  28. RAS Condition 2 – agreements on same terms except for date, volume, price and delivery

  29. The RAS will only include transaction or agreements on the same terms except for date, volume, price and delivery.
  30. Non-financial dealings denominated in different currencies

  31. IRPD transactions that are non-financial transactions (such as the sale or purchase of tangible goods) which involve payment in different currencies can be aggregated in the same RAS, provided the transactions meet all other requirements for a RAS. These transactions/RAS can therefore be reported as one line item in Part A of the Local File.
  32. Agreements on same terms except for date

  33. The reference to ‘same terms except for date’ means that the particular dates on which the transaction or agreement was entered into and obligations are fulfilled do not need to be the same. For example, the following dates do not need to be the same:  
    1. when goods are delivered
    2. when services are provided
    3. when payments are made
    4. when property is transferred.  
  34. A transaction or agreement will not qualify as being part of a RAS if it does not have the same express tenor or duration. For example:  
    1. an agreement under which a loan can only be redeemed by the lender after five years will not be considered to be on the ‘same terms except for date, volume, price and delivery’ as an agreement under which a loan can be redeemed by the lender after one year.
    2. an AUD/USD forward exercisable in nine years and 11 months after its date of effect will not be considered to be on the ‘same terms except for date, volume, price and delivery’ as an AUD/USD forward exercisable in three months after its date of effect.   

    Accordingly, these agreements cannot form part of the same RAS.

    Agreements on same terms except for delivery

  35. The reference to ‘same terms except for delivery’ means there may be variation in the means by which goods or services provided or obtained under the agreements are delivered. For example, agreements to purchase the same kinds of goods which would otherwise be in the same RAS will not fail RAS Condition 2 merely because one of the agreements provides for delivery by ship to the Port of Sydney and another agreement provides for delivery by ship to the Port of Wollongong.
  36. Agreements otherwise on same terms

  37. A transaction or agreement will not be on the same terms as another agreement merely because the transaction occurring under both agreements is of the same Transaction Category, for example, a fixed-for-floating interest rate swap.
  38. RAS Condition 2 also means that a RAS will not include agreements on reverse, or mirror, terms. For example, the following agreements cannot be aggregated for Part A or otherwise included together under a RAS, even if the terms of the agreements are a perfect mirror or reverse of each other:        
    1. an interest rate swap where the reporting entity pays floating payments and receives fixed payments cannot be aggregated with an interest rate swap where the reporting entity pays fixed payments and receives floating payments.
    2. a borrowing by the reporting entity cannot be aggregated with a loan by the Reporting Entity.
    3. a purchase of goods cannot be aggregated with a sale of the same kind of goods.   
  39. Other examples of IRPDs that will not be considered to be ‘on the same terms except for date, volume, price and delivery’ include:        
    1. agreements for sale or purchase of different kinds of tangible property – refer to paragraphs 33-35 below
    2. agreements granting rights to use different intellectual property, for example, different patents
    3. agreements covering financial dealings in different currencies, for example, a loan of Australian dollars versus a loan of US dollars, or a USD/AUD forward versus a Euro/AUD forward
    4. agreements for raising funds in different ways, for example, borrowing under a loan versus obtaining funds by issue of promissory notes
    5. agreements providing guarantee, indemnity or insurance of a different kind of liability or risk, for example, an indemnity of liabilities arising under warranty of products sold to Australian customers versus an indemnity of loans provided to Australian customers
    6. agreements that have different express provisions for termination or damages, for example, agreements that provide for termination by a party only upon payment default versus agreements that may be terminated by a party other than upon default
    7. agreements that are expressly able to be assigned versus agreements that expressly provide they are not able to be assigned.

    Agreements for sale or purchase of same kind of goods, commodities or raw materials

  40. Agreements will not be treated as for the sale or purchase of different kinds of tangible property merely because the agreements cover different particular goods, commodities or raw materials, as long as the goods, commodities and raw materials are of the same kind.
  41. For example, agreements covering the following kind of goods, commodities or raw materials may be included in a RAS if the RAS Conditions are otherwise satisfied:  
    1. agreements for the sale or purchase of different specific blends of refined oil
    2. agreements for the sale or purchase of different qualities or physical condition of brown coal
    3. agreements for the sale or purchase of different models of refrigerators and freezers
    4. agreements for the sale or purchase of similar kinds of pharmaceutical products.  
  42. Examples of agreements that would not be treated as for the sale or purchase of the same kind of goods, commodities or raw materials include:  
    1. an agreement for the sale or purchase of aluminium versus copper
    2. an agreement for the sale or purchase of bauxite versus aluminium
    3. an agreement for the sale or purchase of refrigerators versus computers
    4. an agreement for the sale or purchase of various over-the-counter medications versus various medical devices.

    Special rules for banks in relation to RAS Condition 2

  43. Special rules apply to banks which permit, subject to certain conditions, the inclusion of the following transactions in a single RAS if the RAS conditions are otherwise met:  
    1. short term derivatives with different tenors
    2. short term ordinary borrowings or ordinary loans with different tenors
    3. qualifying FX derivatives with differing currency pairs.  

    This means that a variation of RAS Condition 2 may apply to a bank’s qualifying derivatives, loans or borrowings (see paragraphs 48–58 below).

    RAS Condition 3 – The transactions covered by the agreement must be on revenue account

  44. The transactions covered by the agreement must be on revenue account. Transactions of a capital nature for Australian tax purposes do not qualify for inclusion in a RAS. For example, the assignment of a patent to an IRP cannot be included in a RAS if the assignment is on capital account for taxation purposes.
  45. The distinction between a transaction on revenue account and a transaction on capital account for Australian income tax purposes is explained in the instructions to Question 13 of the IDS.
  46. Whether dealings are capital or revenue in nature is a matter to be decided based on the facts and circumstances of each case. The leading Australian case on this topic is Sun Newspapers Ltd and Associated Newspapers Ltd v FC of T (1938) 61 CLR 337; 5 ATD 87.
  47. This case established that expenditure incurred in establishing, replacing and enlarging the profit yielding structure (i.e. the business entity/structure) is of a capital nature and should be contrasted with working or operating expenses incurred to operate the business or profit yielding structure. The test laid down in the Sun newspapers case requires the following three factors to be considered and weighed in deciding whether expenditure is capital or of a capital nature:        
    1. The nature of the benefit or advantage obtained or secured by the incurrence of the expenditure, for example, whether the expenditure secures an enduring benefit.
    2. The manner in which the benefit or advantage so obtained or secured is to be relied upon or enjoyed.
    3. The means adopted to obtain or secure the benefit or advantage.  

    There are many other decisions of the Australian courts applying these principles in Sun Newspapers to various cases. For more information, refer to ATO guidance such as taxation rulings. We strongly recommend that you obtain appropriate guidance or professional advice in relation to the particular facts and circumstances of your case.

    RAS Condition 4 – Derivatives / guarantees / insurance for Reporting Entity’s related party exposures / liabilities / risk cannot be included in same RAS as other derivatives / guarantees / insurance

  48. Agreements for derivatives, guarantees/indemnities or insurance/reinsurance that are hedging, guaranteeing or insuring specific exposures, liabilities or risks arising in connection with the reporting entity’s related party dealings cannot be included in the same RAS as:  
    1. agreements for derivatives which are not hedging or offsetting specific liabilities or exposures, or
    2. agreements for derivatives, guarantees/indemnities or insurance/reinsurance that are hedging, guaranteeing or insuring specific kinds of exposures, liabilities or risks which are not exposures, liabilities or risks arising in connection with the reporting entity’s related party dealings.
  49. For the purpose of applying RAS Condition 4, agreements for derivatives, guarantees/indemnities or insurance/reinsurance that are hedging, guaranteeing or insuring specific exposures, liabilities or risks arising in connection with the reporting entity’s related party dealings will not include:  
    1. agreements for derivatives hedging or offsetting specific exposures or liabilities of the IRP derivative counterparty arising in connection with a related party transaction which is not with the reporting entity (or a member of the reporting entity’s Australian consolidated or MEC group)
    2. agreements for guarantees or indemnities where the reporting entity guarantees or indemnifies a liability of the IRP counterparty arising in connection with a related party dealing which is not with the Reporting Entity (or a member of the reporting entity’s Australian consolidated or MEC group)
    3. agreements for insurance or reinsurance where the reporting entity provides insurance or reinsurance to the IRP counterparty to insure or reinsure risks arising in connection with a related party dealing which is not with the reporting Entity (or a member of the reporting entity’s Australian consolidated or MEC group).

    Consequences of an IRP agreement being part of a RAS

  50. The consequences of an IRP agreement forming part of a RAS are:  
    1. the reporting entity must show the aggregated values at Part A for all the agreements in the RAS in relation to each Transaction Category covered by the agreement (subject to the special rule for OBUs that OB activities and non-OB activities cannot be aggregated)
    2. in Part A, the reporting entity must indicate  
      1. the transaction details shown at Part A for the relevant Transaction Category are part of a RAS and whether one of the special rules for banks has been applied
      2. which of the following number bands represent the number of agreements in the RAS during the income year  
        1. 2–5
        2. 6–50
        3. 51 or more  
  51. if the reporting entity is an OBU under subsection 128AE(2) of the Income Tax Assessment Act 1936 (ITAA 1936) or section 717–710 of the Income Tax Assessment Act 1997 (ITAA 1997), whether the transactions at Part A are an OB activity under sections 121D and 121EAA of the ITAA 1936
  52. in Part B, the reporting entity is only required to provide written agreement documentation for a material representative agreement in the RAS.
  53. Refer to paragraphs 44–45 below for the principles for determining material representative agreements. 
  54. Material representative agreements

  55. A consequence of an agreement being part of a RAS is that the reporting entity will only be required to provide written agreement documentation for a material representative agreement in the RAS in Part B for the associated transaction in Part A.
  56. The principles for determining a material representative agreement are:  
    1. the documentation for the agreement does not contain materially fewer terms and conditions than documentation for other agreements in the RAS
    2. the documentation for the agreement is not expressed in a more abbreviated or summarised form than documentation for other agreements in the RAS
    3. the agreement documentation is for an agreement which fairly reflects the size and impact of the agreements in the RAS.

    Special rules that apply to OBUs and banks

  57. Special rules apply to certain transactions where the reporting entity is an OBU or a bank.
  58. OBUs: OB and non-OB activity

  59. Where a reporting entity is an OBU under subsection 128AE(2) of the ITAA 1936 or section 717-710 of the ITAA 1997, agreements for transactions which are OB activities cannot be included in the same RAS as agreements for transactions which are not OB activities. This means that any agreement for a transaction which constitutes an OB activity under section 121D of the ITAA 1936 cannot be included in the same RAS as an agreement for a transaction which the reporting entity has chosen to not be an OB activity under section 121EAA.
  60. Banks and short-term ordinary borrowings and ordinary loans: variation of RAS Condition 2

  61. A special rule applies to banks which permits the inclusion of ordinary borrowings and ordinary loans with different tenors in a single RAS where:  
    1. the borrowings or loans are not at call or repayable on demand by the lender
    2. the tenor of the borrowings or loans is 12 months or less. 
    3. Where this special rule applies, RAS Condition 2 will be that agreements are on the same terms except for date, volume, price, delivery and tenor.
  62. This special rule can only be used where the reporting entity or a member of the reporting entity’s consolidated group has an unconditional or a conditional Australian banking licence.
  63. In Part A, the reporting entity will indicate if the special short-term tenor rule for banks has been applied.
  64. Banks and short-term derivatives: variation of RAS Condition 2

  65. A special rule that applies to banks permits the inclusion of derivatives with different tenors or durations in a single RAS for derivatives with a tenor or duration of 12 months or less.
  66. Where this special rule applies, RAS Condition 2 will be that agreements are on the same terms except for date, volume, price, delivery and tenor.
  67. This special rule can only be used where the reporting entity or a member of the reporting entity’s consolidated group has an unconditional or a conditional Australian banking licence.
  68. In Part A, the reporting entity will indicate if the special short term tenor rule for banks has been applied.
  69. Banks and FX derivatives: variation of RAS Condition 2

  70. A special rule applies to banks which permits the inclusion of qualifying FX derivatives with differing currency pairs in a single RAS. Where this special rule applies, RAS Condition 2 will be that agreements are on the same terms except for date, volume, price, delivery, tenor and currency pair.
  71. The conditions for applying this special rule are:  
    1. the reporting entity or a member of the reporting entity’s consolidated group must have an unconditional or a conditional Australian banking licence
    2. the internal rules of the reporting entity’s global group must provide that an entity (FX management entity) in the global accounting consolidated group is responsible for pooling and externally hedging the banking group’s FX risk
    3. the FX management entity enters into FX derivatives that back out, to the FX management entity, the FX exposure for third party customer exposures of the related counterparty (qualifying FX derivatives).
  72. For the avoidance of doubt, the reference in paragraph 56.c. to FX derivatives backing out the FX exposure for third party customer exposures of the related counterparty:   
    1. includes FX derivatives which offset or effectively hedge:  
      1. a portion of the FX exposure for third party customer exposures of the related counterparty; or
      2. aggregated FX exposure for third party customer exposures of the related counterparty.
    2. does not include FX derivatives which:  
      1. offset or effectively hedge exposures which are not FX exposure for third party customer exposures of the related counterparty, or
      2. deliberately or materially overhedge the FX exposure for the relevant third party customer exposures of the related counterparty.   

Appendix 9: Glossary

Table 78: Glossary

Term

Meaning

AUD

Australian dollars

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 currency

For SGEs which have not made a functional currency choice in accordance with subdivision 960-D of the ITAA 1997, any non-Australian dollar currency.

For SGEs which have made a functional currency choice in accordance with subdivision 960-D of the ITAA 1997, AUD and any other currency other than the foreign currency chosen in accordance with that subdivision.

Foreign currency deferred payment arrangements (FCDPA)

Transactions involving an obligation for payment in a foreign currency where the payment is not made on the date the payment is due, and the payment is deferred and remains outstanding and unsatisfied.

It follows a FCDPA transaction would no longer be in existence when all of the amounts payable had been satisfied, including through an intercompany loan with an IRP (which would need to be separately reported as an IRPD Debt Interests transaction).

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 1 or 2; but there are audited general purpose financial reports prepared in relation to the reporting entity; and you have a reconciliation pack to eliminate the effect of other entities that are not members of the reporting entity's consolidated or MEC group for Australian tax purposes, those financial reports and the reconciliation pack.
  • If there are no reports satisfying the requirements in 1, 2, or 3, 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, 3, or 4, but there are management accounts, those reports.
  • If there are no reports satisfying the requirements in 1, 2, 3, 4, or 5, but there are other reports, those reports.     

 

International related party

See 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

Issue of ordinary shares

As described for the exclusion list category 'Issue of ordinary shares' in Local File/Master File 2023.

Low value/low risk sale and purchase tangible trading stock agreements

As described for the exclusion list category 'Low value/low risk sale and purchase tangible trading stock agreements' in Local File/Master File 2023

Low value/low risk service agreements

As described for the exclusion list category 'Low value/low risk service agreements' in Local File/Master File 2023.

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

Reimbursement under employee secondment agreements

As described for the exclusion list category 'Reimbursement under employee secondment agreements' in Local File/Master File 2023.

Relevant agreement series

As described in Appendix 8.

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

Appendix 10: Foreign and other jurisdiction names and codes

A – C: Foreign countries or jurisdictions names and codes

Alpha-2 code

Country or jurisdiction

AF

Afghanistan

AX

Aland Islands

AL

Albania

DZ

Algeria

AS

American Samoa

AD

Andorra

AO

Angola

AI

Anguilla

AQ

Antarctica

AG

Antigua and Barbuda

AR

Argentina

AM

Armenia

AW

Aruba

AT

Austria

AZ

Azerbaijan

BS

Bahamas

BH

Bahrain

BD

Bangladesh

BB

Barbados

BY

Belarus

BE

Belgium

BZ

Belize

BJ

Benin

BM

Bermuda

BT

Bhutan

BO

Bolivia

BQ

Bonaire, Saint Eustatius and Saba Islands

BA

Bosnia and Herzegovina

BW

Botswana

BV

Bouvet Island

BR

Brazil

IO

British Indian Ocean Territory

VG

British Virgin Islands

BN

Brunei Darussalam

BG

Bulgaria

BF

Burkina Faso

BI

Burundi

CV

Cabo Verde

KH

Cambodia

CM

Cameroon

CA

Canada

KY

Cayman Islands

CF

Central African Republic

TD

Chad

CL

Chile

CN

China

CO

Colombia

MP

Commonwealth of the Northern Mariana Islands

KM

Comoros

CD

Congo, Democratic Republic of (was Zaire)

CG

Congo, Republic of

CK

Cook Islands

CR

Costa Rica

CI

Côte d'Ivoire (Ivory Coast)

HR

Croatia (Hrvatska)

CU

Cuba

CW

Curacao

CY

Cyprus

CZ

Czech Republic

D – M: Foreign countries or jurisdictions names and codes

Alpha-2 code

Country or jurisdiction

DK

Denmark

DJ

Djibouti

DM

Dominica

DO

Dominican Republic

EC

Ecuador

EG

Egypt

SV

El Salvador

GQ

Equatorial Guinea

ER

Eritrea

EE

Estonia

SZ

Eswatini

ET

Ethiopia

FK

Falkland Islands

FO

Faroe Islands

FJ

Fiji

FI

Finland

FR

France

GF

French Guiana

PF

French Polynesia

TF

French Southern Territories

GA

Gabon

GM

Gambia

GE

Georgia

DE

Germany

GH

Ghana

GI

Gibraltar

GR

Greece

GL

Greenland

GD

Grenada

GP

Guadeloupe

GU

Guam

GT

Guatemala

GG

Guernsey

GN

Guinea

GW

Guinea-Bissau

GY

Guyana

HT

Haiti

VA

Holy See (Vatican City State)

HN

Honduras

HK

Hong Kong

HR

Hrvatska (Croatia)

HU

Hungary

IS

Iceland

IN

India

ID

Indonesia

IR

Iran

IQ

Iraq

IE

Ireland

IM

Isle of Man, The

IL

Israel

IT

Italy

CI

Ivory Coast (Côte D'Ivoire)

JM

Jamaica

JP

Japan

JE

Jersey

JO

Jordan

KZ

Kazakhstan

KE

Kenya

KI

Kiribati

KP

Korea, Democratic People's Republic of (North Korea)

KR

Korea, Republic of (South Korea)

KW

Kuwait

KG

Kyrgyz Republic

LA

Laos

LV

Latvia

LB

Lebanon

LS

Lesotho

LR

Liberia

LY

Libya

LI

Liechtenstein

LT

Lithuania

LU

Luxembourg

MO

Macau (Macao)

MG

Madagascar

MW

Malawi

MY

Malaysia

MV

Maldives

ML

Mali

MT

Malta

MQ

Martinique

MR

Mauritania

MU

Mauritius

YT

Mayotte

MX

Mexico

FM

Micronesia, Federated States of

MD

Moldova

MC

Monaco

MN

Mongolia

ME

Montenegro

MS

Montserrat

MA

Morocco

MZ

Mozambique

MM

Myanmar (Burma)

N – Z: Foreign countries or jurisdictions names and codes

Alpha-2 code

Country or jurisdiction

NA

Namibia

NR

Nauru

NP

Nepal

NL

Netherlands

NC

New Caledonia

NZ

New Zealand

NI

Nicaragua

NE

Niger

NG

Nigeria

NU

Niue

KP

North Korea (Korea, Democratic People's Republic of)

NO

Norway

OM

Oman

PK

Pakistan

PW

Palau

PS

Palestinian Territories

PA

Panama

PG

Papua New Guinea

PY

Paraguay

PE

Peru

PH

Philippines

PN

Pitcairn Island

PL

Poland

PT

Portugal

PR

Puerto Rico

QA

Qatar

MK

Republic of North Macedonia

MH

Republic of the Marshall Islands

RE

Reunion

RO

Romania

RU

Russian Federation

RW

Rwanda

BL

Saint Barthélemy

SH

Saint Helena

KN

Saint Kitts and Nevis

LC

Saint Lucia

MF

Saint Martin (French Part)

SX

Sint Maarten (Dutch Part)

PM

Saint Pierre and Miquelon

VC

Saint Vincent and The Grenadines

WS

Samoa

SM

San Marino

ST

Sao Tome and Principe

SA

Saudi Arabia

SN

Senegal

RS

Serbia

SC

Seychelles

SL

Sierra Leone

SG

Singapore

SK

Slovak Republic (Slovakia)

SI

Slovenia

SB

Solomon Islands

SO

Somalia

ZA

South Africa

GS

South Georgia and the South Sandwich Islands

KR

South Korea (Korea, Republic of)

SS

South Sudan

ES

Spain

LK

Sri Lanka

SD

Sudan

SR

Suriname

SJ

Svalbard and Jan Mayen Islands

SE

Sweden

CH

Switzerland

SY

Syria

TW

Taiwan

TJ

Tajikistan

TZ

Tanzania

TH

Thailand

TL

Timor-Leste

TG

Togo

TK

Tokelau

TO

Tonga

TT

Trinidad and Tobago

TN

Tunisia

TR

Turkiye (Turkey)

TM

Turkmenistan

TC

Turks and Caicos Islands

TV

Tuvalu

UG

Uganda

UA

Ukraine

AE

United Arab Emirates

GB

United Kingdom

US

United States of America

UM

United States Minor Outlying Islands

VI

United States Virgin Islands

UY

Uruguay

UZ

Uzbekistan

VU

Vanuatu

VA

Vatican City State (Holy See)

VE

Venezuela

VN

Vietnam

WF

Wallis and Futuna

EH

Western Sahara

YE

Yemen

ZM

Zambia

ZW

Zimbabwe

Additional countries or jurisdictions names and codes

Alpha-2 code

Country or jurisdiction

AU

Australia

XX

Not resident of any country for taxation purposes

 

Table60

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