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IRPD use rights

Last updated 4 July 2023

Table 10: IRPD use rights

Code

Description of transaction category

RUIP

Rights to use IP

Any IRPDs for the use or right to use intellectual property of a revenue (non-capital) nature.

Intellectual property includes:

  • trademarks
  • patents
  • registered designs
  • copyright
  • other intellectual property or similar property or rights including rights granted or protected under foreign law
  • interests in or rights granted in respect of any of the above, for example, a license to use a copyright.

 

ORSR

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

Any IRPDs for the use or supply, or rights to use, supply or receive, where the consideration for such use, supply or rights is a royalty under section 6(1) of the ITAA 1936 excluding transactions covered by:

  • Rights to use IP (RUIP).

Where there is a conflict between the definition of royalty in subsection 6(1) and the definition in an applicable double tax agreement, use the definition in the double tax agreement (see section 4(2) of the International Tax Agreements Act 1953).

This can include IRPD arrangements involving:

  • the use or right to use industrial, commercial or scientific equipment
  • the supply of scientific, technical, industrial or commercial knowledge or information

the supply of any services or assistance ancillary and subsidiary to, and furnished as a means of enabling application or enjoyment of the use of intellectual property or of the above kinds of equipment, knowledge or information.

LF

Licence fees

Any IRPDs involving grant or use of a licence, excluding transactions covered by:

  • Rights to use IP (RUIP) or
  • Other Rights to use, supply or receive where consideration is a Royalty under section 6(1) (ORSR).

The term ‘licence’ has its ordinary meaning.

RRP

Rent of real property

Any IRPDs for the rent or lease of, or in the nature of renting or leasing, real property including land and buildings.

The term ‘rent’ has its ordinary meaning.

HLPE

Hire or lease of plant or equipment

Any IRPDs for the hire or lease of, or in the nature of hiring and leasing, plant or equipment.

The terms ‘lease’ or ‘leasing’ and ‘hire’ or ‘hiring’ have their ordinary meaning.

LHORP

Lease or hire of other property or rights

Any IRPDs for the hire or lease of, or in the nature of hiring and leasing, property or rights other than:

  • real property including land and buildings
  • plant or equipment.

The terms ‘lease’ or ‘leasing’ and ‘hire’ or ‘hiring’ have their ordinary meaning.

Any amounts provided at any of the below questions should be reported in whole dollars and cents.

  1. Transaction Identifier

Show the Transaction ID for the transaction being reported.

(LCMSF31)

  1. Related Transaction Identifier(s)

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

(LCMSF206)

  1. What is the transaction category?

Select the transaction category for the IRPD transaction.

(LCMSF32)

  1. Is this transaction part of a RAS?

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

Otherwise indicate False.

(LCMSF33)

  1. How many transactions are part of the RAS?

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

  • Low (2–5)
  • Moderate (6–50)
  • High (51 or more)

(LCMSF35)

  1. Australian counterparty name

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

(LCMSF207)

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

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

(LCMSF83 and LCMSF84)

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

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

The full name to be shown is the complete name of the IRP non-resident counterparty entity. While this would be expected to usually correspond with the name of the relevant party in any associated written agreement documentation, the full correct name of the entity should be shown at Part A even if this is not exactly the same as the name used in any associated written agreement documentation.

(LCMSF37)

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

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

(LCMSF38)

  1. Was the transaction/ RAS entered into by the non-resident counterparty in the course of its business operations carried on through a permanent establishment in a different country to its country of tax residence?

Indicate True if the transaction/RAS was entered into by the non-resident counterparty in the course of its business operations carried on through a PE in a different country to its country of tax residence.

Otherwise indicate False.

(LCMSF208)

  1. Country of permanent establishment of non-resident counterparty

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

Show the country code of the PE through which the non-resident counterparty entered into the transaction/RAS. This code must not be the same as the code reported at Question 9 (LCMSF38) for the country of tax residence of the non-resident counterparty.

(LCMSF209)

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

If an amount of a capital nature was paid by the reporting entity in connection with this transaction/RAS during the income year, show this amount based on the reporting entity’s accounting records.

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

(LCMSF39)

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

If an amount of a capital nature was received by the reporting entity in connection with this transaction/RAS during the income year, show this amount based on the reporting entity’s accounting records.

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

(LCMSF40)

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

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

Otherwise indicate False.

(LCMSF85)

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

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

Otherwise indicate False.

(LCMSF86)

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

Rights to use IP (RUIP) / Other rights to use, supply or receive where consideration is a royalty under section 6(1) (ORSR) / licence fees (LF)

Show the amount the reporting entity deducted for income tax purposes for royalties or other losses or outgoings in connection with this transaction/RAS during the income year based on the reporting entity’s income tax records, including any fees or consideration payable for:

  • a licence or other use or right to use intellectual property such as trademarks or patents
  • the use or right to use industrial, commercial or scientific equipment
  • the supply of scientific, technical, industrial or commercial knowledge or information
  • the supply of any services or assistance ancillary and subsidiary to, and furnished as a means of enabling application or enjoyment of the use of intellectual property or of the above kinds of equipment, knowledge or information.

Show zero if the reporting entity deducted no amount for royalties or other losses or outgoings in connection with this transaction/RAS during the income year.

IRPD use rights

Show the amount of expenditure not of a capital nature for income tax purposes in connection with this transaction/RAS during the income year based on the reporting entity’s accounting records, including any rent or hire fees.

Show zero if there was no amount of expenditure not of a capital nature in connection with this transaction/RAS during the income year.

(LCMSF41)

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

Rights to use IP (RUIP) / Other rights to use, supply or receive where consideration is a royalty under section 6(1) (ORSR) / licence fees (LF)

Show the amount the reporting entity returned as assessable royalties or other income in connection with this transaction/RAS during the income year based on the reporting entity’s income tax records, including any fees or consideration receivable for:

  • a licence or other use or right to use intellectual property such as trademarks or patents
  • the use or right to use industrial, commercial or scientific equipment
  • the supply of scientific, technical, industrial or commercial knowledge or information
  • the supply of any services or assistance ancillary and subsidiary to, and furnished as a means of enabling application or enjoyment of the use of intellectual property or of the above kinds of equipment, knowledge or information.

Show zero if the reporting entity returned no assessable royalties or other income in connection with this transaction/RAS during the income year.

IRPD use rights

Show the amount of revenue not of a capital nature for income tax purposes in connection with this transaction/RAS during the income year based on the reporting entity’s accounting records, including any rent or hire fees.

Show zero if there was no amount of revenue not of a capital nature in connection with this transaction/RAS during the income year.

(LCMSF42)

  1. Average balance of debt interests issued (Inbound Borrowings)

Not applicable.

(LCMSF210)

  1. Capitalised interest deducted

Not applicable.

(LCMSF211)

  1. Average balance of debt interests held (Outbound Loans)

Not applicable.

(LCMSF212)

  1. Capitalised interest returned

Not applicable.

(LCMSF213)

  1. Book values

Not applicable.

(LCMSF214)

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

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

Otherwise indicate False.

(LCMSF44)

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

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

Otherwise indicate False.

(LCMSF45)

  1. Is the debt interest (including borrowing/loan) interest-free?

Not applicable

(LCMSF237)

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

Indicate True if you have entered into a foreign currency deferred payment arrangement in relation to this transaction.

Otherwise indicate False.

(LCMSF215)

  1. Foreign Currency Reporting Type

This question applies only if you answered True to Question 26.

Indicate the type of foreign currency deferred payment arrangement entered into:

1 = short term foreign currency deferred payment arrangements

2 = longer term foreign currency deferred payment arrangements

If you have indicated 1, then you only need to provide the Foreign Currency CodeExternal Link at Question 28.

If you have indicated 2, then you need to provide the Foreign Currency CodeExternal Link at Question 28 and report the relevant associated IRPD foreign currency deferred payment arrangement transaction.

(LCMSF216)

  1. Foreign Currency Code

This question applies only if you answered True to Question 26 and indicated that you entered into a short term or longer term foreign currency deferred payment arrangement at Question 27.

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

(LCMSF217)

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

Not applicable

(LCMSF87)

  1. Foreign Currency Code

Not applicable

(LCMSF219)

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

Not applicable

(LCMSF43)

  1. Foreign Currency Code

Not applicable

(LCMSF221)

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

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

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

(LCMSF46)

  1. What level of transfer pricing documentation has been prepared for this transaction/RAS?

The level of transfer pricing documentation refers to the aggregate dollar amount of this transaction/RAS for which the reporting entity has prepared relevant transfer pricing documentation, expressed as a percentage of total dollar value of this transaction/RAS.

1 = 0%

2 = 1% to less than 25%

3 = 25% to less than 50%

4 = 50% to less than 75%

5 = 75% to less than 100%

6 = 100%

If this transaction/RAS meets the conditions for one of the following Simplified Transfer Pricing Record Keeping (STPRK) options, outlined in PCG 2017/2 Simplified Transfer Pricing Record Keeping Options, show the codes for the STPRK option applied to the transaction/RAS:

7 = STPRK (Materiality)

8 = STPRK (Small Taxpayers)

9 = STPRK (Distributors)

(LCMSF47)

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

Always indicate False if the transaction category is not ordinary borrowings or ordinary loans.

(LCMSF88)

  1. If the reporting entity is a bank and this transaction is in a RAS, has the special short-term tenor rule for short term derivatives been applied to this RAS?

Always indicate False if the transaction category is not derivatives.

(LCMSF128)

  1. If the reporting entity is a bank and this transaction is in a RAS, has the special rule for FX derivatives been applied to this RAS?

Always indicate False if the transaction category is not derivatives.

(LCMSF129)

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

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

Otherwise indicate False.

(LCMSF63)

  1. Is this transaction/RAS covered by a category on the Exclusions List?

Indicate False, since none of the categories on the exclusions list can apply to these IRPD Use Rights.

(LCMSF48)

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

Not applicable.

(LCMSF49)

  1. Transaction Comments

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

(LCMSF222)

Reporting example: IRPD use rights

Example 7: Licence of patents and trademarks with Swiss and Irish IRPs

The facts are the same as the facts in Example 5.

The agreement for the licence to use the patents is not with the same IRP as the agreement for the right to use the trademarks. Even if the agreements were with the same IRP they would not be in the same RAS because they grant rights to different intellectual property and are not on the same terms except for date, volume, price and delivery. For more information about the RAS rules refer to Appendix 8.

The amounts payable by Aus Co and the amounts deducted for income tax purposes by Aus Co for the income year are shown in the table below. 

Table 11: Aus Co income tax amounts payable and amounts deducted
Table 11: Aus Co income tax amounts payable and amounts deducted

Nature of amount payable by Aus Co

Amounts payable

Amounts deducted

Whether amount is of a capital or revenue nature for income tax purposes

Amount payable up front for 10 year patent licence from Swiss Co

A$10m

0

Capital

Annual licence fee payable for patent licence from Swiss Co

A$5m

A$5m

Revenue

Annual licence fee payable for right to use trademarks from Irish Co

US$15m

AUD equivalent of US$15m

Revenue

Although the licence fee payable by Aus Co to Irish Co for the right to use trademarks is payable in US dollars, Aus Co does not return any assessable foreign exchange gains or deduct any foreign exchange losses because Aus Co pays Irish Co the annual licence fee of US$15 million on the specified due date for payment under the agreement.

Aus Co did not provide or obtain any non-monetary consideration in relation to the licence to use the patents or the right to use the trademarks.

Aus Co has applied the transfer pricing methodology ‘Comparable uncontrolled price method’ to all payments made for the licence to use the patents and for the right to use the trademarks.

Aus Co has prepared relevant contemporaneous transfer pricing documentation for 100% of the licence to use the patents and the right to use the trademarks.

In accordance with the instructions for IRPD Services arrangements, Aus Co has completed the Questions for the connected research and development services (RD) transaction, as shown in Table 7 of Example 5

In accordance with the instructions for IRPDs involving disposal or acquisition of intangible property or rights, Aus Co completes the Questions for the Assignment of IP (ASIP) transaction for the connected assignment of the patents to Swiss Co, as shown in Table 55 of Example 16.

Aus Co completes the Questions for the Rights to Use IP (RUIP) transactions/RAS for the licence to use the patents and the licence to use the trademarks based on its accounting records as shown in the following tables.

Table 12: Completed entry for Example 7 – 10-year patent licence from Swiss Co (Rights to use IP)
Table 12: Completed entry for Example 7 – 10-year patent licence from Swiss Co (Rights to use IP)

Question no.

Question label

Response

1

Transaction Identifier

[Transaction ID]

2

Related Transaction Identifier(s)

[Transaction IDs for RD transaction in Table 7 of Example 5 and ASIP transaction in Table 55 of Example 16]

3

Transaction Category

RUIP

4

Is this transaction part of a RAS?

False

5

How many transactions are part of the RAS?

Na

6

Australian counterparty name

[Australian counterparty name]

7

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

[ABN or TFN]

8

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

Swiss Co

9

Tax residence of the IRP non-resident counterparty to the transaction/RAS

CH

10

Was the transaction/RAS entered into by the non-resident counterparty in the course of its business operations carried on through a permanent establishment in a different country to its country of tax residence?

False

11

Country of permanent establishment counterparty

Na

12

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

10000000

13

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

0

14

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

False

15

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

False

16

Amount of expenditure (not of a capital nature for income tax purposes) for the transaction/RAS that the reporting entity deducted for income tax purposes

5000000

17

Amount of revenue (not of a capital nature for income tax purposes) for the transaction/RAS that the reporting entity returned as assessable for income tax purposes

0

18

Average balance of debt interests issued (Inbound Borrowings)

Na

19

Capitalised interest deducted

Na

20

Average balance of debt interests held (Outbound loans)

Na

21

Capitalised interest returned

Na

22

Book values

Na

23

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

False

24

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

False

25

Is the debt interest (including borrowing/loan) interest-free?

Na

26

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

False

27

Foreign Currency Reporting Type

Na

28

Foreign Currency Code

Na

29

Amount of foreign exchange losses deducted for the transaction/RAS

Na

30

Foreign Currency Code

Na

31

Amount of foreign exchange gains returned for the transaction/RAS

Na

32

Foreign Currency Code

Na

33

What transfer pricing/capital asset pricing methodology has been applied to the transaction/RAS?

CUP

34

What level of transfer pricing documentation has been prepared for this transaction/RAS?

6

35

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

False

36

If the reporting entity is a bank and this transaction is in a RAS, has the special short-term tenor rule for short term derivatives been applied to this RAS?

False

37

If the reporting entity is a bank and this transaction is in a RAS, has the special rule for FX derivatives been applied to this RAS?

False

38

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

False

39

Is this transaction/RAS covered by a category on the Exclusions List?

False

40

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

Na

41

Transaction Comments

[Comments]

 

Table 13: Completed entry for Example 7 – Right to use trademarks from Irish Co (Rights to use IP)
Table 13: Completed entry for Example 7 – Right to use trademarks from Irish Co (Rights to use IP)

Question no.

Question label

Response

1

Transaction Identifier

[Transaction ID]

2

Related Transaction Identifier(s)

[Transaction IDs]

3

Transaction Category

RUIP

4

Is this transaction part of a RAS?

False

5

How many transactions are part of the RAS?

Na

6

Australian counterparty name

[Australian counterparty name]

7

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

[ABN or TFN]

8

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

Irish Co

9

Tax residence of the IRP non-resident counterparty to the transaction/RAS

IE

10

Was the transaction/RAS entered into by the non-resident counterparty in the course of its business operations carried on through a permanent establishment in a different country to its country of tax residence?

False

11

Country of permanent establishment counterparty

Na

12

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

0

13

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

0

14

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

False

15

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

False

16

Amount of expenditure (not of a capital nature for income tax purposes) for the transaction/RAS that the reporting entity deducted for income tax purposes

Australian dollar equivalent of US1.5m

17

Amount of revenue (not of a capital nature for income tax purposes) for the transaction/RAS that the reporting entity returned as assessable for income tax purposes

0

18

Average balance of debt interests issued (Inbound Borrowings)

Na

19

Capitalised interest deducted

Na

20

Average balance of debt interests held (Outbound loans)

Na

21

Capitalised interest returned

Na

22

Book values

Na

23

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

False

24

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

False

25

Is the debt interest (including borrowing/loan) interest-free?

Na

26

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

False

27

Foreign Currency Reporting Type

Na

28

Foreign Currency Code

Na

29

Amount of foreign exchange losses deducted for the transaction/RAS

Na

30

Foreign Currency Code

Na

31

Amount of foreign exchange gains returned for the transaction/RAS

Na

32

Foreign Currency Code

Na

33

What transfer pricing/capital asset pricing methodology has been applied to the transaction/RAS?

CUP

34

What level of transfer pricing documentation has been prepared for this transaction/RAS?

6

35

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

False

36

If the reporting entity is a bank and this transaction is in a RAS, has the special short-term tenor rule for short term derivatives been applied to this RAS?

False

37

If the reporting entity is a bank and this transaction is in a RAS, has the special rule for FX derivatives been applied to this RAS?

False

38

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

False

39

Is this transaction/RAS covered by a category on the Exclusions List?

False

40

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

Na

41

Transaction Comments

[Comments]

 

End of example

 

Example 8: Grant of rights to use patents and trademarks for zero monetary consideration

The facts are the same as the facts in Example 6.

In accordance with the instructions for IRPD use rights, Aus Co will also need to complete the Questions for the Rights to Use IP (RUIP) transaction, for the rights granted by Aus Co to Singapore Co to use its patents and trademarks for zero monetary consideration.

Aus Co potentially did obtain non-monetary consideration in relation to its grant of rights to use its patents and trademarks to Singapore Co, being the obtaining of any 'procurement services' agreed to be provided by Singapore Co to Aus Co.

Aus Co has not applied any transfer pricing methodology to this RUIP transaction.

Aus Co has not prepared transfer pricing documentation for this RUIP transaction.

Aus Co's agreement to grant rights to use its patents and trademarks to Singapore Co is not covered by any category on the exclusions list.

Table 14: Completed entry for Example 8 – Grant of rights to use patents and trademarks for zero monetary consideration
Table 14: Completed entry for Example 8 – Grant of rights to use patents and trademarks for zero monetary consideration

Question no.

Question label

Response

1

Transaction Identifier

[Transaction ID]

2

Related Transaction Identifier(s)

[Transaction IDs for OS transaction in Table 9 of Example 6 and reported OS transaction in connection with 'toll manufacturing' arrangement with UK parent]

3

Transaction category

RUIP

4

Is this transaction part of a RAS?

False

5

How many transactions are part of the RAS?

Na

6

Australian counterparty name

[Australian counterparty name]

7

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

[ABN or TFN]

8

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

Singapore Co

9

Tax residence of the IRP non-resident counterparty to the transaction/RAS

SG

10

Was the transaction/RAS entered into by the non-resident counterparty in the course of its business operations carried on through a permanent establishment in a different country to its country of tax residence?

False

11

Country of permanent establishment counterparty

Na

12

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

0

13

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

0

14

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

False

15

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

False

16

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

0

17

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

0

18

Average balance of debt interests issued (Inbound Borrowings)

Na

19

Capitalised interest deducted

Na

20

Average balance of debt interests held (Outbound loans)

Na

21

Capitalised interest returned

Na

22

Book values

Na

23

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

False

24

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

True

25

Is the debt interest (including borrowing/loan) interest-free?

Na

26

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

False

27

Foreign Currency Reporting Type

Na

28

Foreign Currency Code

Na

29

Amount of foreign exchange losses deducted for the transaction/RAS

Na

30

Foreign Currency Code

Na

31

Amount of foreign exchange gains returned for the transaction/RAS

Na

32

Foreign Currency Code

Na

33

What transfer pricing/capital asset pricing methodology has been applied to the transaction/RAS?

UNKT

34

What level of transfer pricing documentation has been prepared for this transaction/RAS?

1

35

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

False

36

If the reporting entity is a bank and this transaction is in a RAS, has the special short term tenor rule for short term derivatives been applied to this RAS?

False

37

If the reporting entity is a bank and this transaction is in a RAS, has the special rule for FX derivatives been applied to this RAS?

False

38

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

False

39

Is this transaction/RAS covered by a category on the Exclusions List?

False

40

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

Na

41

Transaction Comments

[Comments]

 

End of example

QC72969