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

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

Examples include:

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

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.
Assessable foreign exchange gains and deductible foreign exchange losses for income tax purposes are determined under Division 775 of the ITAA 1997 or, if applicable, under the taxation of financial arrangements (TOFA) provisions in Division 230 of the ITAA 1997.
For more guidance on entities covered by TOFA and the operation of TOFA, refer to Guide to the taxation of financial arrangements (TOFA).
In other scenarios assessable foreign exchange gains and deductible foreign exchange losses are determined under the provisions in Subdivisions 775-B to 775-E and Subdivisions 960-C and 960-D of the ITAA 1997.
Foreign exchange gain refers to a foreign exchange gain attributable to fluctuations in a currency exchange rate you make as a result of a forex realisation event under the provisions.
Foreign exchange loss refers to a foreign exchange loss attributable to fluctuations in a currency exchange rate you make as a result of a forex realisation event under the provisions.
Under Subdivision 775-B of the ITAA 1997 there are five main types of Forex realisation events:

event 1 happens if you dispose of foreign currency, or a right to receive foreign currency, to another entity
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)
event 3 happens if you cease to have an obligation to receive foreign currency
event 4 happens if you cease to have an obligation to pay foreign currency
event 5 happens if you cease to have a right to pay foreign currency.

There are also special rules:

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

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

Appendix 7: Special rules for reporting foreign exchange gains and losses in Local File – Part A

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.

Reporting FX gains and losses calculated using the financial reports method under TOFA

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

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.

FX gains and losses for transactions on capital account (financial institutions)

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.
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.

FX gains and losses for transactions on revenue account (financial institutions)

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

A special reporting rule applies to IRPDs involving deferred foreign currency payment arrangements for the following kinds of local file Transaction categories:

sale/purchase of tangible property of a revenue nature to/from the IRP
provision/acquisition of services to/from the IRP
IRP use rights granted to/from an IRP
share based employment recharge to/from an IRP

What are foreign currency deferred payment arrangements (FCDPA)?

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.

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).

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).

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.

Longer term deferred foreign currency payment arrangements

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).

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)

For any IRP transaction/RAS in the following transaction category or Transaction category groupings:

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

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.
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.
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.
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).
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:

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
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
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%)
transactions on capital account (i.e., not on revenue account).

Outlined below are:

General principles on providing IRP agreements
What comprises written agreements in various scenarios?
Relevant Agreement Series
Material representative agreements
Special rules that apply to OBUs and banks

General principles on providing IRP agreements

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

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:

an agreement provided in Part B or an identified agreement previously provided to the ATO
an indication by the reporting entity in Part B that either:

there is no written agreement documentation covering the transaction shown at Part A
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.

If a single written agreement covers more than one kind of transaction category then:

the information required in Part B will need to be provided for each kind of transaction category covered by the agreement
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

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:

the title of the written agreement or amendment agreement
the year in which the agreement or amendment agreement was provided to the ATO
whether the previously provided written agreement or amendment agreement was part of your local file lodgment for a previous reporting period.

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.

No requirement to create written agreement but must indicate in Part B if no written agreement exists

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.

Must indicate if written agreement cannot be obtained by Reporting Entity from related overseas counterparty

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.

What comprises written agreements in various scenarios?

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.
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.
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:

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
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

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.
If this scenario applies and the reporting entity chooses to use this option, the reporting entity will:

indicate in Part B there is no written agreement documentation covering the transaction shown at Part A
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

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.
For these kinds of transactions, an additional condition needs to be satisfied:

derivatives
guarantees or indemnities
insurance or reinsurance.

In these cases, refer to RAS Condition 4.

Where an IRPD transaction or agreement forms part of a RAS:

in Part A, the dollar values for each kind of transaction category covered by the RAS are aggregated
the criteria in the Exclusions List are applied on the basis of the aggregated amounts
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?

For a transaction or agreement series to qualify as a RAS, these four conditions must be met:

transaction or agreements must be with the same IRP
transaction or agreements must be on the same terms except for date, volume, price and delivery
the transactions must be on revenue account (i.e., are not on capital account)
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.

The principles for determining a material and representative agreement of a RAS are outlined below at paragraphs 39–40.
There are also special rules if the reporting entity is an OBU or a bank:

the special rules for OBUs with respect to OB and non-OB activities are outlined below at paragraph 46
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

The RAS will only include transaction or agreements between the same parties.
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.

RAS Condition 2 – agreements on same terms except for date, volume, price and delivery

The RAS will only include transaction or agreements on the same terms except for date, volume, price and delivery.

Non-financial dealings denominated in different currencies

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.

Agreements on same terms except for date

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:

when goods are delivered
when services are provided
when payments are made
when property is transferred.

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:

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.
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

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.

Agreements otherwise on same terms

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.
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:

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.
a borrowing by the reporting entity cannot be aggregated with a loan by the Reporting Entity.
a purchase of goods cannot be aggregated with a sale of the same kind of goods.

Other examples of IRPDs that will not be considered to be ‘on the same terms except for date, volume, price and delivery’ include:

agreements for sale or purchase of different kinds of tangible property – refer to paragraphs 33-35 below
agreements granting rights to use different intellectual property, for example, different patents
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
agreements for raising funds in different ways, for example, borrowing under a loan versus obtaining funds by issue of promissory notes
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
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
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

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.
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:

agreements for the sale or purchase of different specific blends of refined oil
agreements for the sale or purchase of different qualities or physical condition of brown coal
agreements for the sale or purchase of different models of refrigerators and freezers
agreements for the sale or purchase of similar kinds of pharmaceutical products.

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:

an agreement for the sale or purchase of aluminium versus copper
an agreement for the sale or purchase of bauxite versus aluminium
an agreement for the sale or purchase of refrigerators versus computers
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

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:

short term derivatives with different tenors
short term ordinary borrowings or ordinary loans with different tenors
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

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.
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.
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.
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:

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.
The manner in which the benefit or advantage so obtained or secured is to be relied upon or enjoyed.
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

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:

agreements for derivatives which are not hedging or offsetting specific liabilities or exposures, or
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.

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:

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)
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)
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

The consequences of an IRP agreement forming part of a RAS are:

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)
in Part A, the reporting entity must indicate

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
which of the following number bands represent the number of agreements in the RAS during the income year

2–5
6–50
51 or more

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
in Part B, the reporting entity is only required to provide written agreement documentation for a material representative agreement in the RAS.
Refer to paragraphs 44–45 below for the principles for determining material representative agreements.

Material representative agreements

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.
The principles for determining a material representative agreement are:

the documentation for the agreement does not contain materially fewer terms and conditions than documentation for other agreements in the RAS
the documentation for the agreement is not expressed in a more abbreviated or summarised form than documentation for other agreements in the RAS
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

Special rules apply to certain transactions where the reporting entity is an OBU or a bank.

OBUs: OB and non-OB activity

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.

Banks and short-term ordinary borrowings and ordinary loans: variation of RAS Condition 2

A special rule applies to banks which permits the inclusion of ordinary borrowings and ordinary loans with different tenors in a single RAS where:

the borrowings or loans are not at call or repayable on demand by the lender
the tenor of the borrowings or loans is 12 months or less.
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.

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.
In Part A, the reporting entity will indicate if the special short-term tenor rule for banks has been applied.

Banks and short-term derivatives: variation of RAS Condition 2

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.
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.
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.
In Part A, the reporting entity will indicate if the special short term tenor rule for banks has been applied.

Banks and FX derivatives: variation of RAS Condition 2

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.
The conditions for applying this special rule are:

the reporting entity or a member of the reporting entity’s consolidated group must have an unconditional or a conditional Australian banking licence
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
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).

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:

includes FX derivatives which offset or effectively hedge:

a portion of the FX exposure for third party customer exposures of the related counterparty; or
aggregated FX exposure for third party customer exposures of the related counterparty.

does not include FX derivatives which:

offset or effectively hedge exposures which are not FX exposure for third party customer exposures of the related counterparty, or
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
D – M: Foreign countries or jurisdictions names and codes
N – Z: Foreign countries or jurisdictions names and codes
Additional countries or jurisdictions 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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