Appendix A: Glossary
Term | Meaning |
|---|---|
Assignment | Assignment in law or in equity, including without limitation assignment by declaration of trust. |
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 or 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 arrangement (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 if all of the amounts payable had been satisfied, including through an intercompany loan (which would need to be separately reported as a IRPD Debt Interests transaction). |
International related party | |
Intellectual property (IP) | Trademark, patent, design, copyright, other intellectual property or similar property or rights. |
International related party dealings (IRPD) | |
Ordinary shares | Shares issued by a company carrying proportionate rights to voting and to profit and capital distributions, and carrying no special rights. |
Relevant agreement series | As described in Local file – Part B: Guidance on providing international related party agreements. |
Appendix B: Transaction categories
Code | Value |
|---|---|
TPRN | Tangible property of a revenue nature |
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 |
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 |
Code | Value |
|---|---|
SBER | Share based employment remuneration |
Code | Value |
|---|---|
CCA | Cost contribution arrangement |
ORIRPD | Other revenue IRPDs |
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 |
Code | Value |
|---|---|
OBL | Ordinary borrowings and 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 |
Code | Value |
|---|---|
IDF | Inward debt factoring |
ODF | Outward debt factoring |
IDSEC | Inward debt securitisation |
ODSEC | Outward debt securitisation |
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 |
Code | Value |
|---|---|
RPRT | Real property |
PLEQ | Plant or equipment |
OTPRTY | Other tangible property |
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 |
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 C: TP method / CAP method
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 D: TP documentation codes / and 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 | |
8 | |
9 | |
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 E: Exclusion list
Code | Value |
|---|---|
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 and low risk service agreements |
LVLRSPT | Low value and 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 F: Foreign countries or jurisdictions names and codes
Additional countries or jurisdictionsAlpha-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 |
Alpha-2 code | Country or jurisdiction |
AU | Australia |
XX | Not resident of any country for taxation purposes |