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 | See IRP and IRPD |
Intellectual property (IP) | Trademark, patent, design, copyright, other intellectual property or similar property or rights. |
International related party dealings (IRPD) | See What is an IRP and 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: Short form codes
Code | Value |
|---|---|
RTI | Restructure or arrangement involving transfer, licence or creation of intangibles |
RCD | Restructure or arrangement involving disposal of ownership interests in you by your controllers (excluding RTI restructures or arrangements) |
RDO | Restructure or arrangement involving disposal of entities or assets (excluding RCD or RTI restructures or arrangements) |
RAO | Restructure or arrangement involving acquisition of entities or assets (excluding RCD, RTI or RDO restructures or arrangements) |
RRF | Restructure or arrangement involving related party financing or refinancing (excluding RCD, RTI, RDO or RAO restructures or arrangements) |
RCB | Restructure or arrangement involving commencement or cessation of business operations (excluding RCD, RTI, RDO, RAO or RRF restructures or arrangements) |
ROT | Other kind of restructure or arrangement |
Code | Value |
|---|---|
BE | Brand equity |
BR | Broadcast rights and like assets |
CI | Scientific, technical, industrial or commercial knowledge or information |
CL | Customer lists, customer data or like rights or assets |
CR | Copyright |
DR | Distribution rights and like assets |
FR | Franchise rights |
GW | Goodwill |
KH | Know how |
NC | Non-compete rights and like assets |
OR | Other rights arising under or protected by foreign laws |
OT | Other intangible assets or rights |
PT | Patents |
RD | Registered designs |
SW | Software |
TM | Trademarks, trade dress, trade names, brand names or like assets |
TS | Trade secrets, secret formulas or recipes or like rights or assets |
Code | Value |
|---|---|
1 | $0 to less than $10 million |
2 | $10 million to less than $50 million |
3 | $50 million to less than $100 million |
4 | $100 million to less than $500 million |
5 | $500 million or greater |
Code | Value |
|---|---|
ATI | Anticipate an increase in Australian tax (including any withholding taxes) as a result of the restructure or arrangement |
NTI | Anticipate no increase or decrease in Australian tax (including any withholding taxes) as a result of the restructure or arrangement |
ATD | Anticipate a decrease in Australian tax (including any withholding taxes) as a result of the restructure or arrangement |
Code | Value |
|---|---|
ELC | Election/choice for tax purposes |
TPC | Change in characterisation of function for transfer pricing purposes |
OCT | Other change in tax treatment |
RPD | Transaction or dealing between related parties (including issue of equity) |
EPD | Transaction or dealing between non-related parties (including issue of equity) |
CEB | 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:
|
COB | 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:
|
CES | Cessation of functions or activities excluding:
|
COM | Commencement of functions or activities excluding:
|
TRM | Transfer of functions or activities excluding:
|
ENE | Incorporating or establishing a new entity |
DTE | Dissolving or terminating an entity |
Code | Value |
|---|---|
ACE | Reporting entity or other Australian member of the CBC reporting group |
IRP | International related party of reporting entity |
OTE | Other entity (excluding ACE or IRP entities) |
Appendix C: 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 D: TP method or 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 E: 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 F: 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 G: Foreign countries or jurisdictions names and codes
Additional countries or jurisdictions
Alpha-2 code | Country or jurisdiction |
|---|---|
AU | Australia |
XX | Not resident of any country for taxation purposes |