Appendices

Assignment in law or in equity, including without limitation assignment by declaration of trust.

Debt receivables including loan receivables.

A debt interest under Division 974 of the ITAA 1997.

An equity interest under Division 974 or section 820-930 of the ITAA 1997.

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.

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).

See IRP and IRPD

Trademark, patent, design, copyright, other intellectual property or similar property or rights.

See What is an IRP and IRPD?

Shares issued by a company carrying proportionate rights to voting and to profit and capital distributions, and carrying no special rights.

As described in Local file – Part B: Guidance on providing international related party agreements.

Restructure or arrangement involving transfer, licence or creation of intangibles

Restructure or arrangement involving disposal of ownership interests in you by your controllers (excluding RTI restructures or arrangements)

Restructure or arrangement involving disposal of entities or assets (excluding RCD or RTI restructures or arrangements)

Restructure or arrangement involving acquisition of entities or assets (excluding RCD, RTI or RDO restructures or arrangements)

Restructure or arrangement involving related party financing or refinancing (excluding RCD, RTI, RDO or RAO restructures or arrangements)

Restructure or arrangement involving commencement or cessation of business operations (excluding RCD, RTI, RDO, RAO or RRF restructures or arrangements)

Other kind of restructure or arrangement

Brand equity

Broadcast rights and like assets

Scientific, technical, industrial or commercial knowledge or information

Customer lists, customer data or like rights or assets

Copyright

Distribution rights and like assets

Franchise rights

Goodwill

Know how

Non-compete rights and like assets

Other rights arising under or protected by foreign laws

Other intangible assets or rights

Patents

Registered designs

Software

Trademarks, trade dress, trade names, brand names or like assets

Trade secrets, secret formulas or recipes or like rights or assets

$0 to less than $10 million

$10 million to less than $50 million

$50 million to less than $100 million

$100 million to less than $500 million

$500 million or greater

Anticipate an increase in Australian tax (including any withholding taxes) as a result of the restructure or arrangement

Anticipate no increase or decrease in Australian tax (including any withholding taxes) as a result of the restructure or arrangement

Anticipate a decrease in Australian tax (including any withholding taxes) as a result of the restructure or arrangement

Election/choice for tax purposes

Change in characterisation of function for transfer pricing purposes

Other change in tax treatment

Transaction or dealing between related parties (including issue of equity)

Transaction or dealing between non-related parties (including issue of equity)

An entity ceasing to carry on functions or activities through its particular branch operations (including where the entity continues carrying on the functions or activities other than through that particular branch) excluding:

• RPD or EPD transactions or dealings

An entity commencing to carry on functions or activities through its particular branch operations (including where the entity was already carrying on the functions or activities other than through that particular branch) excluding:

• RPD or EPD transactions or dealings

Cessation of functions or activities excluding:

• CEB or COB
• RPD or EPD transactions or dealings

Commencement of functions or activities excluding:

• CEB or COB
• RPD or EPD transactions or dealings

Transfer of functions or activities excluding:

• CEB or COB
• RPD or EPD transactions or dealings

Incorporating or establishing a new entity

Dissolving or terminating an entity

Reporting entity or other Australian member of the CBC reporting group

International related party of reporting entity

Other entity (excluding ACE or IRP entities)

Tangible property of a revenue nature

Treasury-related services

Management and administration services

Insurance services

Reinsurance services

Research and development services

Sales and marketing services

Software and IT services

Technical services

Logistics services

Asset management services

Other services

Rights to use IP

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

Licence fees

Rent of real property

Hire or lease of plant or equipment

Lease or hire of other property or rights

Share based employment remuneration

Cost contribution arrangement

Other revenue IRPDs

Cross currency interest rate swap

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

Fixed for floating interest rate swap (not cross currency)

Other interest rate derivative (not cross currency)

Credit default swap

Asset swap

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

Other derivative

Ordinary borrowings and loans (excluding trade financing)

Trade financing

Bonds

Promissory notes

Convertible notes that are debt interests

Convertible shares that are debt interests

Redeemable preference shares that are debt interests

Other kinds of debt interests

Inward debt factoring

Outward debt factoring

Inward debt securitisation

Outward debt securitisation

Guarantee or indemnity of liability under debt interest

Guarantee or indemnity of other kind of liability

Insurance

Reinsurance

Other financial dealings

Real property

Plant or equipment

Other tangible property

Assignment of IP

Issue of ordinary shares

Assignment of ordinary shares

Issue of equity interest other than ordinary shares

Assignment of equity interest other than ordinary shares

Assignment of debts

Assignment of liabilities

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

Assignment of other intangible property or rights

Foreign currency deferred payment arrangement for sale of tangible trading stock

Foreign currency deferred payment arrangement for purchase of tangible trading stock

Foreign currency deferred payment arrangement for provision of services

Foreign currency deferred payment arrangement for acquisition of services

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Apportionment of costs

Apportionment of Income

Comparable uncontrolled price method

Cost-contribution arrangement

Cost-plus method

Fixed mark-up applied to cost

Fixed percentage of resale price

Marginal costing

Profit split method

Resale price method

Transactional net margin method

Transactional net margin method (whole-of-entity)

Other arm's length methods

None

Unknown (transfer pricing method)

Cost price

Directors valuation

Discounted cash flow

Independent valuation

Nil consideration

Quoted market price

Written-down value

Other methods

Unknown (capital asset pricing method)

0%

1% to less than 25%

25% to less than 50%

50% to less than 75%

75% to less than 100%

100%

Simplified transfer pricing record keeping (materiality)

Simplified transfer pricing record keeping (small business)

Simplified transfer pricing record keeping (distributors)

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

Simplified transfer pricing record keeping (technical services)

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

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

Green zone (PCG 2017/1)

Green zone (PCG 2017/4)

Simplified transfer pricing record keeping (technical services)

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

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

Reimbursement under employee secondment agreements

Low value and low risk service agreements

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

Issue of ordinary shares

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

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

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 (Malvinas)

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

Kyrgyzstan

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)

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

Slovakia (Slovak Republic)

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

Turkey

TM

Turkmenistan

TC

Turks and Caicos Islands

TV

Tuvalu

UG

Uganda

UA

Ukraine

AE

United Arab Emirates

GB

United Kingdom

US

United States

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

AU

Australia

XX

Not resident of any country for taxation purposes