For reporting of IRPDs of a financial nature, the term 'financial nature' refers to dealings in financial instruments that would qualify as financial assets or financial liabilities under relevant Australian accounting standards or comparable foreign accounting standards.
Code |
Description of transaction category |
|---|---|
GILDI |
Guarantee or indemnity of liability under a debt interest Any IRPDs in the nature of guarantee or indemnity of liability under a debt interest under Division 974 of the ITAA 1997. The expenditure and revenue for guarantees or indemnity include fees associated with a contract or arrangement under which a party agrees to perform an obligation or discharge a liability of another entity should that entity fail to do so. |
GIOKL |
Guarantee or indemnity of other kind of liability Any IRPDs in the nature of guarantee or indemnity of liability other than under a debt interest under Division 974 of the ITAA 1997. The expenditure and revenue for guarantees or indemnity include fees associated with a contract or arrangement under which a party agrees to perform an obligation or discharge a liability of another entity should that entity fail to do so. |
IN |
Insurance Any IRPDs in the nature of insurance. Insurance is a means by which an entity can protect itself with an insurance company against the risk of loss. Insurance is commonly categorised into general insurance, life insurance and health insurance. If the reporting entity engaged an intermediary (for example, a broker) in arranging its insurance contracts, even if the intermediary was acting as an independent agent, the intermediary is considered to be acting on the reporting entity’s behalf. Therefore, the transactions undertaken by the intermediary on the reporting entity’s behalf should be included in this transaction category. The amounts reported for this transaction category should include the expenditure and revenue that would qualify as expenditure or revenue in relation to insurance contracts under relevant Australian accounting standards or comparable foreign accounting standards (for example, premium revenue and claim recoveries). Expenditure incurred or revenue earned or derived for insurance services with international related parties, including activities associated with the management of insurance contracts (including activities predominantly undertaken through intermediaries), should be shown at transaction category ‘insurance services’. |
REIN |
Reinsurance Any IRPDs in the nature of reinsurance. Reinsurance is a means by which an insurance company can protect itself with other insurance companies against the risk of losses. Therefore, the question relating to reinsurance is applicable only to insurance companies. If the reporting entity engaged an intermediary (for example, a broker) in arranging its reinsurance contracts, even if the intermediary was acting as an independent agent, the intermediary is considered to be acting on the reporting entity’s behalf. Therefore, the transactions undertaken by the intermediary on the reporting entity’s behalf should be included in this transaction category. The amounts reported for this transaction category should include the expenditure and revenue that would qualify as expenditure or revenue in relation to reinsurance contracts under relevant Australian accounting standards or comparable foreign accounting standards (for example, premium revenue and commissions received from reinsurers). Expenditure incurred or revenue earned or derived for reinsurance services with international related parties, including activities associated with the management of reinsurance contracts (including activities predominantly undertaken through intermediaries), should be shown at transaction category ‘reinsurance services’. |
OFD |
Other financial dealings Any IRPDs of a financial nature excluding any of the following transaction categories:
This transaction category does not include dividends or other distributions of profit on ordinary shares or equity interests of a non-revenue nature. For the avoidance of doubt, ordinary shares or equity interests do not include hybrid equity or other arrangements where the characterisation between debt and equity is different under Division 974 of the Income Tax Assessment Act 1997 (ITAA 1997) and your treatment for accounting purposes. |
Do not show your gains or losses from trading in bonds or other financial assets or liabilities at IRPD debt interests (including ordinary loans and borrowings).
You should instead show your gains or losses from trading in bonds or other financial assets or liabilities at OFD 'Other financial dealings'.
Any amounts provided at any of the below questions should be reported in whole dollars and cents.
- Transaction Identifier
Show the Transaction ID for the transaction being reported.
(LCMSF31)
- Related Transaction Identifier(s)
Show all Transaction IDs that are related or directly connected to the transaction being reported.
(LCMSF206)
- What is the transaction category?
Select the transaction category for the IRPD transaction.
(LCMSF32)
- Is this transaction part of a RAS?
If this transaction is covered by an IRPD agreement in a RAS, indicate True.
Otherwise indicate False.
(LCMSF33)
- How many transactions are part of the RAS?
If the transaction is part of a RAS, indicate the applicable range for the number of the transactions in the same RAS that were current during the income year:
- Low (2–5)
- Moderate (6–50)
- High (51 or more)
(LCMSF35)
- Australian counterparty name
Show the full name of the Australian counterparty (which may be the reporting entity itself) to this transaction/RAS.
(LCMSF207)
- ABN or TFN of the Australian counterparty to the transaction/RAS
Show the ABN or TFN or both of the Australian counterparty (which may be the reporting entity itself) to the transaction/RAS.
(LCMSF83 and LCMSF84)
- Name of the IRP non-resident counterparty to the transaction/RAS
Show the full name of the IRP non-resident counterparty to this transaction/RAS.
The full name to be shown is the complete name of the IRP non-resident counterparty entity. While this would be expected to usually correspond with the name of the relevant party in any associated written agreement documentation, the full correct name of the entity should be shown at Part A even if this is not exactly the same as the name used in any associated written agreement documentation.
(LCMSF37)
- Tax residency of the IRP non-resident counterparty to the transaction/RAS
Show the country code for the country of tax residence of the IRP non-resident counterparty to this transaction/RAS.
(LCMSF38)
- Was the transaction/RAS entered into by the non-resident counterparty in the course of its business operations carried on through a permanent establishment in a different country to its country of tax residence?
Indicate True if the transaction/RAS was entered into by the non-resident counterparty in the course of its business operations carried on through a PE in a different country to its country of tax residence.
Otherwise indicate False.
(LCMSF208)
- Country of permanent establishment of non-resident counterparty
This question applies only if you answer True to Question 10.
Show the country code of the PE through which the non-resident counterparty entered into the transaction/RAS. This code must not be the same as the code reported at Question 9 (LCMSF38) for the country of tax residence of the IRP non-resident counterparty to this transaction/RAS.
(LCMSF209)
- Amount of consideration paid (of a capital nature for income tax purposes) for the transaction/RAS
The reporting rules for showing the amount of consideration paid of a capital nature at this question depend on the nature of the IRPs financial dealings.
If an amount of a capital nature was paid by the reporting entity in connection with the guarantee or indemnity, insurance, reinsurance or other financial dealings 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 paid by the reporting entity in connection with the guarantee or indemnity, insurance, reinsurance or other financial dealings transaction/RAS during the income year.
(LCMSF39)
- Amount of consideration received (of a capital nature for income tax purposes) for the transaction/RAS
The reporting rules for showing the amount of consideration received of a capital nature at this question depend on the nature of the IRPs financial dealings.
If an amount of a capital nature was received by the reporting entity in connection with the guarantee or indemnity, insurance, reinsurance or other financial dealings 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 the guarantee or indemnity, insurance, reinsurance or other financial dealings transaction/RAS during the income year.
(LCMSF40)
- Was non-monetary consideration provided (of a capital nature for income tax purposes) for the transaction/RAS?
Indicate True if non-monetary consideration of a capital nature was provided by the reporting entity in connection with this transaction/RAS during the income year.
Otherwise indicate False.
(LCMSF85)
- Was non-monetary consideration obtained (of a capital nature for income tax purposes) for the transaction/RAS?
Indicate True if non-monetary consideration of a capital nature was obtained by the reporting entity in connection with this transaction/RAS during the income year.
Otherwise indicate False.
(LCMSF86)
- Amount of expenditure (not of a capital nature for income tax purposes) for the transaction/RAS
IRP financial dealing is IRP guarantee or indemnity of liability under a debt interest/guarantee or indemnity of other kind of liability
Show the amount of expenditure not of a capital nature for income tax purposes including any guarantee or indemnity fees payable for the guarantee or indemnity IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
Show zero if there was no amount of expenditure not of a capital nature for income tax purposes for the guarantee or indemnity IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
IRP financial dealing is IRP insurance/reinsurance
Show the amount of expenditure not of a capital nature for income tax purposes including any insurance premiums payable for the insurance or reinsurance IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
Show zero if there was no amount of expenditure not of a capital nature for income tax purposes for the insurance or reinsurance IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
IRP financial dealing is IRP other financial dealings
Show the amount of expenditure not of a capital nature for income tax purposes for the other financial dealings IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
Show zero if there was no amount of expenditure not of a capital nature for income tax purposes for the other financial dealings IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
(LCMSF41)
- Amount of revenue (not of a capital nature for income tax purposes) for the transaction/RAS
IRP financial dealing is IRP guarantee or indemnity of liability under a debt interest/guarantee or indemnity of other kind of liability
Show the amount of revenue not of a capital nature for income tax purposes, including any guarantee or indemnity fees received for the guarantee or indemnity IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
Show zero if there was no amount of revenue not of a capital nature for income tax purposes for the guarantee or indemnity IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
IRP financial dealing is IRP insurance/reinsurance
Show the amount of revenue not of a capital nature for income tax purposes, including any premiums received for the insurance or reinsurance IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
Show zero if there was no amount of revenue not of a capital nature for income tax purposes for the insurance or reinsurance IRP transaction/RAS during the income year based on the reporting entity's accounting records.
IRP financial dealing is IRP other financial dealings
Show the amount of revenue not of a capital nature for income tax purposes for the other financial dealings IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
Show zero if there was no amount of revenue not of a capital nature for income tax purposes for the other financial dealings IRP transaction/RAS during the income year based on the reporting entity’s accounting records.
(LCMSF42)
- Average balance of debt interests issued (Inbound Borrowings)
Not applicable.
(LCMSF210)
- Capitalised interest deducted
Not applicable.
(LCMSF211)
- Average balance of debt interests held (Outbound Loans)
Not applicable.
(LCMSF212)
- Capitalised interest returned
Not applicable.
(LCMSF213)
- Book values
Not applicable.
(LCMSF214)
- Was non-monetary consideration provided (not of a capital nature for income tax purposes) for the transaction/RAS?
Indicate True if non-monetary consideration not of a capital nature for income tax purposes was provided by the reporting entity in connection with this transaction/RAS during the income year.
Otherwise indicate False.
(LCMSF44)
- Was non-monetary consideration obtained (not of a capital nature for income tax purposes) for the transaction/RAS?
Indicate True if non-monetary consideration not of a capital nature for income tax purposes was obtained by the reporting entity in connection with this IRP transaction/RAS during the income year.
Otherwise indicate False.
(LCMSF45)
- Is the debt interest (including borrowing/loan) interest-free?
Not applicable
(LCMSF237)
- Did you enter into a deferred foreign currency payment arrangement in relation to this transaction?
Not applicable for this transaction category.
(LCMSF215)
- Foreign Currency Reporting Type
Not applicable for this transaction category.
(LCMSF216)
- Foreign Currency Code
Not applicable for this transaction category.
(LCMSF217)
- Amount of foreign exchange losses deducted for the transaction/RAS
Show the amount of foreign exchange losses deducted for income tax purposes by the reporting entity in connection with this transaction/RAS under Division 775 of the ITAA 1997 or, if applicable, the taxation of financial arrangements (TOFA) provisions in Division 230 of the ITAA 1997 for the income year.
For more information about the circumstances in which foreign exchange gains are assessable and foreign exchange losses are deductible for Australian income tax purposes, refer to Appendix 6.
Show zero if there was no foreign exchange loss deducted for income tax purposes in connection with this transaction/RAS for the income year.
(LCMSF87)
- Foreign Currency Code
Show the Foreign Currency CodeExternal Link in relation to foreign exchange losses deducted for the transaction/RAS
(LCMSF219)
- Amount of foreign exchange gains returned for the transaction/RAS
Show the amount of foreign exchange gains assessable for income tax purposes in connection with this transaction/RAS under Division 775 of the ITAA 1997 or, if applicable, the TOFA provisions in Division 230 of the ITAA 1997 for the income year.
For more information about the circumstances in which foreign exchange gains are assessable and foreign exchange losses are deductible for Australian income tax purposes, refer to Appendix 6.
Show zero if there was no foreign exchange gain assessable for income tax purposes in connection with this transaction/RAS for the income year.
(LCMSF43)
- Foreign Currency Code
Show the Foreign Currency CodeExternal Link in relation to assessable foreign exchange gains for the transaction/RAS
(LCMSF221)
- 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)
- 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%
(LCMSF47)
- If the reporting entity is a bank and this of transaction is in a RAS, has the special short-term tenor rule for ordinary borrowings and ordinary loans been applied to this RAS?
Always indicate False if the transaction category is not ordinary borrowings or ordinary loans.
(LCMSF88)
- If the reporting entity is a bank and this of transaction is in a RAS, has the special short-term tenor rule for short term derivatives been applied to this RAS?
Always indicate False if the transaction category is not derivatives.
(LCMSF128)
- If the reporting entity is a bank and this transaction is in a RAS, has the special short-term tenor rule for FX derivatives been applied to this RAS?
Always indicate False if the transaction category is not derivatives.
(LCMSF129)
- If the reporting entity is an OBU, is this transaction/RAS an OB activity?
If the reporting entity is an OBU and this transaction/RAS is an OB activity under sections 121D and 121EAA of the ITAA 1936, indicate True.
Otherwise indicate False. (LCMSF63)
- Is this transaction/RAS covered by a category on the exclusions list?
Indicate False, since none of the categories on the exclusions list can apply to these kinds of financial dealings.
(LCMSF48)
- What category of the exclusions list applies to this transaction/RAS?
Not applicable.
(LCMSF49)
- Transaction Comments
Provide any relevant comments in respect of the transaction/RAS.
You must provide a short description if the kind of transaction being reported is OFD (Other financial dealings).
(LCMSF222)
Reporting example: Other financial dealings
Example 15: Redeemable Preference Shares that are not debt interests
Aus Co is a company that is resident in Australia for tax purposes.
Aus Co has an income tax year ending 30 June.
Aus Co’s functional currency for Australian tax purposes is Australian dollars.
During the income year, Aus Co issues redeemable preference shares (RPS) worth $200M to an IRP, resident for tax purposes in United Kingdom (UK Co). The RPS have a tenor of more than 10 years and non-cumulative dividends that are payable upon the business meeting particular financial metrics. During the income year, Aus Co pays a dividend on the RPS of A$5m to UK Co. The RPS are classified as equity interests for Div 974 purposes.
Aus Co has not applied any transfer pricing methodology for the payments on the RPS.
Aus Co has not prepared relevant contemporaneous transfer pricing documentation for the payments on the RPS.
Aus Co completes the questions for the IRP transactions/RAS in this example based on its accounting records as shown in the table below.
Question no. |
Question label |
Response |
|---|---|---|
1 |
Transaction Identifier |
[Transaction ID] |
2 |
Related Transaction Identifier(s) |
[Transaction IDs] |
3 |
Transaction category |
OFD |
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 |
UK Co |
9 |
Tax residence of the IRP non-resident counterparty to the transaction/RAS |
GB |
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 |
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 |
Na |
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 |
0 |
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 |
Dividends paid on redeemable preference shares which are not debt interests under Division 974. |
End of example