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Detailed design

How to use electronic lodgment, attachment requirements and message structure table overview.

Last updated 22 December 2024

LCMSF design

We have developed a local file and master file XML schema (LCMSF) and associated validation rules to enable reporting entities to submit their local file (now incorporating the short form) and master file to the ATO.

The design of the LCMSF allows for the local file's 3 components, the master file and the financial accounts to be submitted independently of each other.

The LCMSF comprises the following sections:

You should also refer to the Appendices for various relevant codes used for reporting as part of the lodgment.

Electronic lodgment

How to lodge

CBC statements (the CBC report, master file and local file) must be lodged via one of the following ATO approved channels:

CBC statements must be submitted via the above channels using a validly generated XML file, otherwise the lodgment will not be considered valid. This XML file is generated by your business management software (tax reporting or accounting software) using the ATO provided XML schema. Additionally, the XML file must adhere to our validation rules and other technical requirements.

You may need to make enquires with your software provider as to whether they support lodging CBC reporting statements to the ATO.

If the valid lodgments are not received by the due date, increased failure to lodge penalties may be imposed. You may request a deferral by emailing CBCReporting@ato.gov.au if you have difficulty in meeting the due date.

For more information on:

Amendments

When making an amendment to a previously lodged statement (or part thereof), refer to the Amendments section of our Country-by-country reporting webpage.

Amendments for income periods starting prior to 1 January 2024 may be made using V 3.0 until 1 January 2026. After this time, V 3.0 will be deactivated and amendments must be made using V 4.0.

Cancelling lodgments

If you would like to cancel a lodgment that has been submitted, email the CBC Reporting team.

Attachments

No particular attachment naming convention is enforced, noting filenames:

  • must be unique
  • cannot exceed 255 characters
  • cannot contain the following special characters: <, >, :, ", /, , |, ?, *.
  • are not case sensitive.

There's a maximum of 500 attachments per lodgment, where the size of any single attachment cannot exceed 20MB. All attachments embedded in the XML file must also be referenced at the appropriate LCMSF element depending on the type of attachment.

Table 3 outlines the types of attachments that are accepted. Multiple attachments can be embedded for each type (except for the organisational structure diagram which is limited to one attachment):

Table 3: Supported attachment types

Attachment code

Attachment type

MSTR

Master file

LFSFO

Organisational structure diagram

LFSFS

Step plan for the restructure

LFPBI

IRP agreement

LFPBA

APA

LFPBR

Ruling

LFFIN

Financial accounts

Table 4 lists the supported attachment formats that can be embedded within the XML file (using BASE64 encoding). Attachments cannot contain active content (macros, JavaScript, etc.) and must not be password protected.

Table 4: Supported attachment formats

File Extension

File type

DOC

Microsoft Word Binary File Format

DOCX

Office Open XML

XLS

Excel Binary File Format

XLSX

Office Open XML

PDF

Portable Document Format

ODT

OpenDocument Text

ODS

OpenDocument Spreadsheet

Message structure table

The following tables provide an overview of the LCMSF. The question IDs relate to the associated elements provided in the message structure table (MST) provided to digital service providers.

Reporting party information

Table 5: Statement information

Question

Question ID

Valid values

Comments

Amendment

LCMSF1

True or False

Mandatory question:

  • indicates whether this lodgment is an amendment to a previous lodgment
  • amended lodgments do not include those lodgments where additional statements (or parts thereof) are being lodged for the first time.

The Reporting entity declaration is required if the statement is submitted by the reporting entity (that is the Intermediary details have not been provided).

Table 6: Reporting entity declaration

Question

Question ID

Valid values

Comments

Reporting entity declaration statement accepted indicator

LCMSF55

True or False

I declare that the information transmitted in this report is to my knowledge true and correct and that I am authorised to make this declaration.

Reporting entity declaration signature date

LCMSF56

YYYY–MM–DD

The actual date on which the declaration is signed by the reporting entity

Reporting entity declaration signatory identifier

LCMSF57

A user login, a full name or an email address

Maximum of 200 characters

Table 7: Reporting period

Question

Question ID

Valid values

Comments

Income year

LCMSF236

YYYY

Mandatory question

The income year of the reporting entity to which this statement relates

Reporting period start date

LCMSF142

YYYY–MM–DD

Mandatory question

The start date of the income year of the reporting entity. If the reporting entity has a substituted accounting period, the start date of the income year must be the start date of that substituted accounting period.

Reporting period end date

LCMSF143

YYYY–MM–DD

Mandatory question

The end date of the income year of the reporting entity. If the reporting entity has a substituted accounting period, the end date of the income year must be the end date of that substituted accounting period.

Entity information

Reporting entity information

Table 8: Reporting entity information

Question

Question ID

Valid values

Comments

Reporting entity ABN

LCMSF7

ABN

A valid ABN

Reporting entity TFN

LCMSF65

TFN

Mandatory question

A valid TFN

Reporting entity name

LCMSF8

Legal name of the entity

Mandatory question

Maximum of 200 characters

Reporting entity email

LCMSF21

Email address

Mandatory question

Maximum of 200 characters

Must be a valid email address

Reporting entity phone

LCMSF22

Mobile or landline

Mandatory question

Maximum of 16 characters

Is the reporting entity the head entity of a tax consolidated group?

LCMSF15

True or False

Mandatory question

Is the reporting entity the provisional head entity of a Multiple entry consolidated (MEC) group?

LCMSF16

True or False

Mandatory question

Is the reporting entity an Offshore banking unit (OBU)?

LCMSF61

True or False

Mandatory question

Global parent entity information

Table 9: Global parent entity information

Question

Question ID

Valid values

Comments

Is the reporting entity the global parent entity?

LCMSF66

True or False

Mandatory question

If True, go to Master file section

If False, go to LCMSF11

Global parent entity name

LCMSF11

Legal name of the entity

Must be provided if LCMSF66 is False

Maximum of 200 characters

Global parent entity tax jurisdiction

LCMSF12

Country code

Must be provided if LCMSF66 is False

Global parent entity ABN

LCMSF9

ABN

If LCMSF12 is 'AU' (Australia), a valid ABN or TFN (or both) is required

Global parent entity TFN

LCMSF10

TFN

If LCMSF12 is 'AU' (Australia), a valid ABN or TFN (or both) is required

Global parent entity TIN

LCMSF194

TIN

If LCMSF12 is not 'AU' (Australia), a Tax Identification Number (TIN) is required

Master file

Table 10: Master file lodgment criteria

Question

Question ID

Valid values

Comments

Does this submission include details regarding your master file?

LCMSF138

True or False

Mandatory question

If True, go to LCMSF81

If False, go to CBC report section

Has the Commissioner of Taxation, by notice in writing, exempted you from providing the master file for this reporting period?

LCMSF81

True or False

If True, go to CBC report section

If False, go to LCMSF121

Have you been granted a replacement reporting period for the master file?

LCMSF121

True or False

If True, replacement reporting period dates must be provided

If False, go to LCMSF196

Replacement reporting period start date

LCMSF122

YYYY–MM–DD

The start date of the replacement reporting period

Replacement reporting period end date

LCMSF123

YYYY–MM–DD

The end date of the replacement reporting period

How is the master file for your global group being lodged?

LCMSF196

1 or 2

1 = Lodgment to the ATO via the reporting entity

2 = Lodgment to the ATO via another entity

Is your lodgment of the master file also on behalf of other entities forming part of your global accounting group (outside your tax consolidated group)?

LCMSF76

True or False

Required if LCMSF196 = 1

If True, LCMSF77 or LCMSF78 and LCMSF233 must be provided

Entity ABN(s)

LCMSF77

ABN

Either valid ABNs or TFNs must be provided. Provide the ABN or the TFN for each entity forming part of your global accounting group but outside your tax consolidated group. The ABN or TFN (or both) for each entity must be provided together as a set with the entity name.

Entity TFN(s)

LCMSF78

TFN

Either valid ABNs or TFNs must be provided. Provide the ABN or the TFN for each entity forming part of your global accounting group but outside your tax consolidated group. The ABN or TFN (or both) for each entity must be provided together as a set with the entity name.

Entity name(s)

LCMSF233

Legal name of entity

Provide the entity name for each entity forming part of your global accounting group but outside your tax consolidated group as a set with its ABN or TFN (or both).

Please confirm that you have attached the master file

LCMSF124

True or False

Required if LCMSF196 = 1 and must be True

The master file should meet the information requirements as outlined in Annexe I of the OECD GuidanceExternal Link

Filename(s) for the master file

LCMSF197

Filename(s) including extension

Required if LCMSF196 = 1 and at least one filename must be provided

See Attachments

Entity ABN

LCMSF19

ABN

Applicable if LCMSF196 = 2

Either a valid ABN or TFN (or both) must be provided

Entity TFN

LCMSF20

TFN

Applicable if LCMSF196 = 2

Either a valid ABN or TFN (or both) must be provided

Entity name

LCMSF232

Legal name of entity

Required if LCMSF196 = 2

CBC report notification

Table 11: CBC report – notification

Question

Question ID

Valid values

Comments

Does this submission include details regarding your CBC report?

LCMSF139

True or False

Mandatory question

If True, go to LCMSF69

If False, go to Local file section

Has the Commissioner, by notice in writing, exempted you from providing the CBC report for this reporting period?

LCMSF69

True or False

If True, go to Local file section

If False, go to LCMSF125

Have you been granted a replacement reporting period for the CBC report?

LCMSF125

True or False

If True, replacement reporting period dates must be provided

If False, go to LCMSF114

Replacement reporting period start date

LCMSF126

YYYY–MM–DD

The start date of the replacement reporting period

Replacement reporting period end date

LCMSF127

YYYY–MM–DD

The end date of the replacement reporting period

Are the details you are submitting regarding the CBC report also on behalf of other entities forming part of your global accounting group but outside your tax consolidated group?

LCMSF114

True or False

If True, LCMSF115 or LCMSF116 and LCMSF235 must be provided

If False, go to LCMSF199

Entity ABN(s)

LCMSF115

ABN

Either valid ABNs or TFNs must be provided. Provide the ABN or the TFN for each entity forming part of your global accounting group but outside your tax consolidated group. The ABN or TFN (or both) for each entity must be provided together as a set with the entity name.

Entity TFN(s)

LCMSF116

TFN

Either valid ABNs or TFNs must be provided. Provide the ABN or the TFN for each entity forming part of your global accounting group but outside your tax consolidated group. The ABN or TFN (or both) for each entity must be provided together as a set with the entity name.

Entity name(s)

LCMSF235

Legal name of entity

Provide the entity name for each entity forming part of your global accounting group but outside your tax consolidated group as a set with its ABN or TFN (or both).

How is the CBC report for your global group being lodged?

LCMSF199

1, 2, or 3

1 = Lodgment to the ATO via the reporting entity

2 = Lodgment to the ATO via another entity

3 = Lodgment via an overseas jurisdiction

Are you filing the CBC report as a surrogate parent entity with the filing intended to meet a CBC reporting obligation in other jurisdictions?

LCMSF140

True or False

Required if LCMSF199 = 1

Entity ABN

LCMSF72

ABN

Applicable if LCMSF199 = 2

Either a valid ABN or TFN (or both) must be provided

Entity TFN

LCMSF73

TFN

Applicable if LCMSF199 = 2

Either a valid ABN or TFN (or both) must be provided

Entity name

LCMSF234

Legal name of Entity

Required if LCMSF199 = 2

Foreign entity name

LCMSF71

Legal name of Entity

Required if LCMSF199 = 3

Foreign entity TIN

LCMSF201

TIN

Required if LCMSF199 = 3

Foreign entity tax jurisdiction

LCMSF74

Country code

Required if LCMSF199 = 3

Local file

Table 12: Local file

Question

Question ID

Valid values

Comments

Does this submission include details regarding your local file?

LCMSF137

True or False

Mandatory question

If True, go to LCMSF117

If False, go to Intermediary section

Has the Commissioner, by notice in writing, exempted you from providing the local file for this reporting period?

LCMSF117

True or False

If True, go to Intermediary section

If False, go to LCMSF119

Which parts of the local file are you lodging in this submission?

LCMSF119

Local file – short form, Local file – Part A, Local file – Part B, Financial accounts

Required if LCMSF137 is True and LCMSF117 is False

At least one value must be provided

Filename(s) for the highest quality financial accounts for the reporting period

LCMSF230

Filename(s) of attachment(s), including extension

Required if Financial accounts indicated at LCMSF119

At least one filename must be provided

See Attachments

Is your lodgment of the Local file – Part A being made as part of the ‘administrative solution’?

LCMSF68

True or False

Must be provided if LCMSF119 = Local file – Part A

Administrative solution

Have you been granted a replacement reporting period for the local file?

LCMSF120

True or False

If True, replacement reporting period dates must be provided

Replacement reporting period start date

LCMSF13

YYYY–MM–DD

The start date of the replacement reporting period

Replacement reporting period end date

LCMSF14

YYYY–MM–DD

The end date of the replacement reporting period

Local file – short form

This section must be completed if you have selected that you will be providing the local file – short form as part of this submission at LCMSF119.

Table 13: Local file – short form

Question

Question ID

Valid values

Comments

Did you engage in IRP transactions or dealings listed on the short form exceptions list for the reporting period?

LCMSF27

True or False

Mandatory question

Did you have less than $2m in aggregate IRPDs for the reporting period?

LCMSF28

True or False

Mandatory question

What is an IRP and IRPD?

Did you meet the criteria for the Small taxpayers STPRK option for the reporting period?

LCMSF29

True or False

Mandatory question

Small taxpayers STPRK option

Did you meet the criteria for the Materiality STPRK option for the reporting period?

LCMSF30

True or False

Mandatory question

Materiality STPRK option

How many main business lines and functions did you engage in during the income year?

LCMSF250

Number

Mandatory question

Description of main business line and function during the income year

LCMSF251

Text

Mandatory question

Description for each main business line or function

Maximum of 10,000 characters

Strategies deployed in main business line or function during the income year

LCMSF252

Text

Mandatory question

Strategies deployed for each main business line or function

Maximum of 10,000 characters

Description of extent to which main business line or function overlaps with or complements other main business lines or functions during the income year

LCMSF253

Text

Required if LCMSF250 = 2 or more (i.e. more than one business line or function)

Maximum of 10,000 characters

Key competitors for main business line or function during the income year

LCMSF254

Text

Mandatory question

Key competitors for each main business line or function

Maximum of 1,000 characters

Did any personnel employed in your business or operations effectively report to overseas personnel during the income year?

LCMSF255

True or False

Mandatory question

If True, go to LCMSF256

If False, go to LCMSF273

Full name of the individual personnel who effectively reported to overseas personnel during the income year

LCMSF256

Full name

Non-mandatory question for each of your individual personnel reporting overseas

Maximum of 200 characters

Job title of the individual personnel who effectively reported to overseas personnel during the income year

LCMSF257

Text

Required if LCMSF255 is True

Job title for each of your individual personnel reporting overseas

Maximum of 200 characters

Full name of the entity which employed or engaged the individual personnel who effectively reported to overseas personnel during the income year

LCMSF258

Legal name of the entity

Required if LCMSF255 is True

Name of entity which employed each of your individual personnel reporting overseas

Maximum of 200 characters

TFN of the entity which employed or engaged the individual personnel who effectively reported to overseas personnel during the income year

LCMSF259

TFN

Required if LCMSF255 is True

Provide the TFN or ABN (or both) for the employing entity of each of your individual personnel reporting overseas.

Either a valid ABN or TFN (or both) must be provided unless the entity is a non-resident entity that does not have an ABN or TFN.

ABN of the entity which employed or engaged the individual personnel who effectively reported to overseas personnel during the income year

LCMSF260

ABN

Required if LCMSF255 is True

Provide the ABN or TFN (or both) for the employing entity of each of your individual personnel reporting overseas.

Either a valid ABN or TFN (or both) must be provided unless the entity is a non-resident entity that does not have an ABN or TFN.

How many different individual overseas personnel did your individual personnel effectively report to during the income year?

LCMSF261

Number

Required if LCMSF255 is True

Provide the number of each of your individual personnel reporting overseas

Full name of the individual overseas personnel to whom your individual personnel effectively reported during the income year

LCMSF262

Full name

Non-mandatory question for each overseas personnel to whom your individual personnel reported

Maximum of 200 characters

Job title of the individual overseas personnel to whom your individual personnel effectively reported during the income year

LCMSF263

Text

Required if LCMSF255 is True

Job title for each overseas personnel to whom your individual personnel reported

Maximum of 100 characters

Country of residence of the individual overseas personnel to whom your individual personnel effectively reported during the income year

LCMSF264

Country code

Non-mandatory question for each overseas personnel to whom your individual personnel reported

Description of the function and activities of your business or operations for which your individual personnel effectively reported to the individual overseas personnel during the income year

LCMSF265

Text

Required if LCMSF255 is True

Description of the function and activities of your business or operations for which each of your individual personnel reported to the individual overseas personnel

Maximum of 1,000 characters

Full name of the entity which employed or engaged the individual overseas personnel to whom your individual personnel effectively reported during the income year

LCMSF266

Legal name of the entity

Required if LCMSF255 is True

Name of entity which employed each overseas personnel to whom your individual personnel reported

Maximum of 200 characters

Country of residence of the entity which employed or engaged the individual overseas personnel to whom your individual personnel effectively reported during the income year

LCMSF267

Country code

Required if LCMSF255 is True

Country of residence of the entity which employed each overseas personnel to whom your individual personnel reported

Country in which the individual overseas personnel to whom your individual personnel effectively reported during the income year maintained their principal office

LCMSF268

Country code

Required if LCMSF255 is True

Country in which the individual overseas personnel, to whom your individual personnel reported, maintained their principal office

Was there any change in your individual personnel’s reporting arrangements during the income year?

LCMSF269

True or False

Required if LCMSF255 is True

Change in the reporting arrangements for each of your individual personnel reporting overseas

If True, go to LCMSF270

If False, go to LCMSF273

Did the change involve a change in the individual overseas personnel to whom your individual personnel effectively reported during the income year?

LCMSF270

True or False

Required if LCMSF255 is True and LCMSF269 is True

When did this particular reporting by your individual personnel to the individual overseas personnel commence during the income year?

LCMSF271

YYYY–MM–DD

Either commencement or cessation date must be provided if LCMSF270 is True

When did this particular reporting by your individual personnel to the individual overseas personnel cease during the income year?

LCMSF272

YYYY–MM–DD

Either commencement or cessation date must be provided if LCMSF270 is True

Have you attached a diagram of your organisational structure during the income year?

LCMSF273

True or False

Mandatory question

Filename of the diagram of your organisational structure during the income year

LCMSF274

Filename of attachment, including extension

Required if LCMSF273 is True

See Attachments

Comments on organisational structure and reporting

LCMSF275

Comments

Provide any comments including any comments in relation to LCMSF269, LCMSF270 or LCMSF273

Maximum of 10,000 characters

Was there any restructure (including change in related party financing) or any new arrangements involving transfer, licence, or creation of intangibles during the current or previous income year (including restructures or arrangements affecting future Australian withholding tax)?

LCMSF276

True or False

Mandatory question

If True, go to LCMSF277

What type of restructure (including any change in related party financing) or new arrangement involving transfer, licence or creation of intangibles occurred during the current or previous income year?

LCMSF277

Restructure codes

Required if LCMSF276 is True

The type of restructure for each significant restructure and new arrangement involving transfer, licence, or creation of intangibles

What kind of intangibles were transferred, licenced, created or otherwise involved in the arrangement or restructure?

LCMSF278

Intangible codes

Required if LCMSF276 is True and restructure code RTI is provided at LCMSF277

Multiple intangible codes should be provided where different types of intangibles are involved in the restructure or new arrangement involving transfer, licence, or creation of intangibles

Description of the restructure (including any change in related party financing) or new arrangement involving transfer, licence or creation of intangibles that occurred during the current or previous income year?

LCMSF301

Text

Required if LCMSF276 is True

Description of each significant restructure or new arrangements involving transfer, licence, or creation of intangibles

Maximum of 1,000 characters

Total capital value of the restructure or arrangement

LCMSF294

Capital Value Code

Required if LCMSF276 is True

Total capital value of each significant restructure or new arrangements involving transfer, licence, or creation of intangibles

Anticipated Australian tax impact of the restructure or arrangement

LCMSF295

Anticipated Australian tax impact code

Required if LCMSF276 is True

Anticipated Australian tax impact of each significant restructure or new arrangements involving transfer, licence, or creation of intangibles

Description of anticipated Australian tax impact of the restructure or arrangement

LCMSF296

Text

Required if LCMSF276 is True

Description of anticipated Australian tax impact of each significant restructure or new arrangements involving transfer, licence, or creation of intangibles

Maximum of 10,000 characters

Description of anticipated global tax impact of the restructure or arrangement

LCMSF305

Text

Required if LCMSF276 is True

Description of anticipated global tax impact of each significant restructure or new arrangements involving transfer, licence, or creation of intangibles

Maximum of 10,000 characters

Commercial context and anticipated commercial impact of the restructure or arrangement

LCMSF297

Text

Required if LCMSF276 is True

Description of commercial context and anticipated commercial impact of each significant restructure or new arrangements involving transfer, licence, or creation of intangibles

Maximum of 10,000 characters

How many steps were involved in the restructure or arrangement (including all connected steps involving overseas related parties)?

LCMSF279

Number

Required if LCMSF276 is True

Provide the number of steps (including all connected steps involving overseas related parties) for each significant restructure or new arrangements involving transfer, licence, or creation of intangibles

Was there any step plan in relation to the steps of the restructure or arrangement?

LCMSF298

True or False

Required if LCMSF276 is True

Have you attached the step plan in relation to the steps of the restructure or arrangement?

LCMSF299

True or False

Required if LCMSF276 is True

Must be True if LCMSF298 is True

Filename(s) of the step plan in relation to the steps of the restructure or arrangement

LCMSF300

Filename(s) of attachment(s), including extension

Required if LCMSF276 and LCMSF299 are True

On what date did the step of the restructure or arrangement occur or start?

LCMSF280

YYYY–MM–DD

Required if LCMSF276 is True

The date of each step of the significant restructure or new arrangements involving transfer, licence, or creation of intangibles (for the number of steps provided at LCMSF279)

Type of step of the restructure or arrangement

LCMSF281

Step type code

Required if LCMSF276 is True

The type of step for each step of the significant restructure or new arrangements involving transfer, licence, or creation of intangibles (for the number of steps provided at LCMSF279)

Description of the step of the restructure or arrangement

LCMSF282

Text

Required if LCMSF276 is True

The description of each step of the significant restructure or new arrangements involving transfer, licence, or creation of intangibles (for the number of steps provided at LCMSF279)

Maximum of 1,000 characters

How many parties to the step of the restructure or arrangement?

LCMSF283

Number

Required if LCMSF276 is True

The number of parties for each step of the significant restructure or new arrangements involving transfer, licence, or creation of intangibles (for the number of steps provided at LCMSF279)

Type of the party to the step of the restructure or arrangement

LCMSF302

Party type code

Required if LCMSF276 is True

The type of the party (for the number of parties provided at LCMSF283) for each step of the significant restructure or new arrangements involving transfer, licence, or creation of intangibles (for the number of steps provided at LCMSF279)

Full name of the party to the step of the restructure or arrangement

LCMSF284

Legal name of the entity

Required if LCMSF276 is True

The name of the party (for the number of parties provided at LCMSF283) for each step of the significant restructure or new arrangements involving transfer, licence, or creation of intangibles (for the number of steps provided at LCMSF279)

Maximum of 200 characters

ABN of the party to the step of the restructure or arrangement

LCMSF303

ABN

Required if LCMSF276 is True and party type code is ACE at LCMSF302 for the party

Either a valid ABN or TFN (or both) must be provided

TFN of the party to the step of the restructure or arrangement

LCMSF304

TFN

Required if LCMSF276 is True and party type code is ACE at LCMSF302 for the party

Either a valid ABN or TFN (or both) must be provided

Country of residence of the party to the step of the restructure or arrangement

LCMSF286

Country code

Required if LCMSF276 is True and if party type code is ACE or IRP at LCMSF302 for the party

Has the party to the step of the restructure or arrangement entered into the step in the course of its business operations carried on through a permanent establishment in a different country to its country of tax residence?

LCMSF287

True or False

Required if LCMSF276 is True and party type code is ACE or IRP at LCMSF302 for the party

Country of the permanent establishment of the party to the step of the restructure or arrangement

LCMSF288

Country code

Required if LCMSF276 and LCMSF287 are True for the party.

Has there been any change in the functional characterisation of any of your operations for transfer pricing purposes in connection with the step of the restructure or arrangement?

LCMSF292

True or False

Required if LCMSF276 is True

Change in functional characterisation of any of your operations for transfer pricing purposes for each step of the significant restructure or new arrangements involving transfer, licence, or creation of intangibles (for the number of steps provided at LCMSF279)

Details of the change in the functional characterisation of your operations for transfer pricing purposes in connection with the step of the restructure or arrangement

LCMSF293

Text

Required if LCMSF276 and LCMSF292 are True

Maximum of 10,000 characters

Local file – Part A

This section must be completed if you have selected that you will be providing the Local file – Part A as part of this submission at LCMSF119.

Table 14: Local file – Part A

Question

Question ID

Valid values

Comments

Transaction Identifier

LCMSF31

Number

Mandatory question

Incrementing number for each transaction that is used to link Part A and Part B.
Provide a unique number for each transaction, beginning at 1.

Related transaction identifier(s)

LCMSF206

Number

See Related transaction identifiers.

Transaction type

LCMSF32

Transaction category

Mandatory question

See Appendix B

Is this transaction part of a relevant agreement series (RAS)?

LCMSF33

True or False

Mandatory question

See Local file – Part B: Guidance on providing international related party agreements

How many transactions are part of the RAS?

LCMSF35

Low or Moderate or High

Applicable if LCMSF33 = True

Low = 2–5
Moderate = 6–50
High = 51 or more

Australian counterparty name

LCMSF207

Legal name of the Entity

Mandatory question

Maximum of 200 characters

Australian counterparty ABN

LCMSF83

ABN

Either a valid ABN or TFN (or both) must be provided

Australian counterparty TFN

LCMSF84

TFN

Either a valid ABN or TFN (or both) must be provided

Non-resident counterparty name

LCMSF37

Legal name of the entity

Mandatory question

Maximum of 200 characters

Non-resident counterparty tax jurisdiction

LCMSF38

Country code

Mandatory question

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?

LCMSF208

True or False

Mandatory question

Country of permanent establishment of non-resident counterparty

LCMSF209

Country code

Required if LCMSF208 is True

Must not be the same country code as provided at LCMSF38

Must not be provided if LCMSF208 is False

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

LCMSF39

$XX,XXX,XXX,XXX.XX

Mandatory question

Amounts reported can contain the full amount in dollars and cents.

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

LCMSF40

$XX,XXX,XXX,XXX.XX

Mandatory question

Amounts reported can contain the full amount in dollars and cents.

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

LCMSF85

True or False

Mandatory question

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

LCMSF86

True or False

Mandatory question

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

LCMSF41

$XX,XXX,XXX,XXX.XX

Mandatory question

Amounts reported can contain the full amount in dollars and cents.

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

LCMSF42

$XX,XXX,XXX,XXX.XX

Mandatory question

Amounts reported can contain the full amount in dollars and cents.

Average balance of debt interests issued (Inbound Borrowings)

LCMSF210

$XX,XXX,XXX,XXX.XX

Applicable only if transaction category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI or OKDI, FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER, FCDSBERI, FCDRUIP, FCDRUIPI, FCDORSR, FCDORSRI, FCDLF, FCDLFI, FCDLHORP or FCDLHORPI

Mandatory if LCMSF211 is provided

Must not be provided if LCMSF212 and LCMSF213 are present

Amounts reported can contain the full amount in dollars and cents.

Capitalised interest deducted

LCMSF211

$XX,XXX,XXX,XXX.XX

Applicable only if transaction category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI, OKDI or FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER, FCDSBERI, FCDRUIP, FCDRUIPI, FCDORSR, FCDORSRI, FCDLF, FCDLFI, FCDLHORP or FCDLHORPI

Mandatory if LCMSF210 is provided

Must not be provided if LCMSF212 and LCMSF213 are present

Amounts reported can contain the full amount in dollars and cents.

Average balance of debt interests held (Outbound Loans)

LCMSF212

$XX,XXX,XXX,XXX.XX

Applicable only if transaction category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI OKDI or FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER, FCDSBERI, FCDRUIP, FCDRUIPI, FCDORSR, FCDORSRI, FCDLF, FCDLFI, FCDLHORP or FCDLHORPI

Mandatory if LCMSF213 is provided

Must not be provided if LCMSF210 and LCMSF211 are present

Amounts reported can contain the full amount in dollars and cents.

Capitalised interest returned

LCMSF213

$XX,XXX,XXX,XXX.XX

Applicable only if transaction category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI,OKDI, FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER, FCDSBERI, FCDRUIP, FCDRUIPI, FCDORSR, FCDORSRI, FCDLF, FCDLFI, FCDLHORP or FCDLHORPI

Mandatory if LCMSF212 is provided

Must not be provided if LCMSF210 and LCMSF211 are present

Amounts reported can contain the full amount in dollars and cents.

Book values

LCMSF214

$XX,XXX,XXX,XXX.XX

Applicable only if transaction category is IDF, ODF, IDSEC or ODSEC

Amounts reported can contain the full amount in dollars and cents.

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

LCMSF44

True or False

Mandatory question

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

LCMSF45

True or False

Mandatory question

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

LCMSF237

True or False

Mandatory if transaction category is OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI, OKDI, FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER, FCDSBERI, FCDRUIP, FCDRUIPI, FCDORSR, FCDORSRI, FCDLF, FCDLFI, FCDLHORP or FCDLHORPI

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

LCMSF215

True or False

See Reporting FX gains and losses for deferred foreign currency payment arrangements for certain qualifying transaction categories

Applicable only if transaction category is TPRN, TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, OS, RRP, HLPE, SBER, RUIP, ORSR, LF or LHORP

Foreign currency reporting type

LCMSF216

1 or 2

Applicable only if LCMSF215 is True

1 = Short term foreign currency deferred payment arrangements

2 = Longer term foreign currency deferred payment arrangements

Foreign currency code

LCMSF217

Currency codesExternal Link

Required if LCMSF216 = 1 or 2

Amount of foreign exchange losses deducted for the transaction

LCMSF87

$XX,XXX,XXX,XXX.XX

Applicable if LCMSF215 is False or blank

Amounts reported can contain the full amount in dollars and cents.

Foreign currency code

LCMSF219

Currency codesExternal Link

Applicable if LCMSF215 is False or blank

Required if amount at LCMSF87 is greater than zero

Amount of foreign exchange gains returned for the transaction

LCMSF43

$XX,XXX,XXX,XXX.XX

Applicable if LCMSF215 is False or blank

Amounts reported can contain the full amount in dollars and cents.

Foreign currency code

LCMSF221

Currency codesExternal Link

Applicable if LCMSF215 is False or blank

Required if amount at LCMSF43 is greater than zero

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

LCMSF46

TP method or CAP method

Mandatory question

See Appendix C

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

LCMSF47

TP Documentation and STPRK codes

Mandatory question

Both TP documentation and STPRK codes can be provided for one transaction

See Local file instructions 2025 for which TP Documentation and STPRK codes may be applicable for the relevant transaction category

See Appendix D

Has the special short term tenor rule for ordinary borrowings and ordinary loans been applied to this transaction?

LCMSF88

True or False

Mandatory question

Must not be True when LCMSF33 is False

Must be False where the transaction category is TPRN, TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, OS, RUIP, ORSR, LF, RRP, HLPE, LHORP, SBER, CCA, ORIRPD, CCIRS, CDCSFFO, FFIRS, OIRD, CDS, CDCS, AS, OD, IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN, OFD, RPRT, PLEQ, OTPRTY, ASIP, IOSH, AOSH, IEIOOS, AQIOS, ASSD, ASSL, ASSBC or ASSOPR

Has the special short term tenor rule for short term derivatives been applied to this transaction?

LCMSF128

True or False

Mandatory question

Must not be True when LCMSF33 is False

Must be False where the transaction category is TPRN, TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, OS, RUIP, ORSR, LF, RRP, HLPE, LHORP, SBER, CCA, ORIRPD, IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN, OFD, RPRT, PLEQ, OTPRTY, ASIP, IOSH, AOSH, IEIOOS, AQIOS, ASSD, ASSL, ASSBC, ASSOPR, OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI,OKDI, FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER, FCDSBERI, FCDRUIP, FCDRUIPI, FCDORSR, FCDORSRI, FCDLF, FCDLFI, FCDLHORP or FCDLHORPI

Has the special short term tenor rule for FX derivatives been applied to this transaction?

LCMSF129

True or False

Mandatory question

Must not be True when LCMSF33 is False

Must be false where the transaction category is TPRN, TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, OS, RUIP, ORSR, LF, RRP, HLPE, LHORP, SBER, CCA, ORIRPD, IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN, OFD, RPRT, PLEQ, OTPRTY, ASIP, IOSH, AOSH, IEIOOS, AQIOS, ASSD, ASSL, ASSBC, ASSOPR, OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI,OKDI, FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER, FCDSBERI, FCDRUIP, FCDRUIPI, FCDORSR, FCDORSRI, FCDLF, FCDLFI, FCDLHORP or FCDLHORPI

Is this transaction an OB Activity?

LCMSF63

True or False

Can only be True when LCMSF32 is True and the transaction category is TPRN, TRS, MAS, INSERV, REINSERV, RD, SAM, SITS, TS, LS, AM, OS, RUIP, ORSR, LF, RRP, HLPE, LHORP, CCA, ORIRPD, CCIRS, CDCSFFO, FFIRS, OIRD, CDS, CDCS, AS, OD, OBL, TFIN, BND, PNOT, CNTDI, CSTDI, RPSDI, OKDI, IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN, OFD, FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER, FCDSBERI, FCDRUIP, FCDRUIPI, FCDORSR, FCDORSRI, FCDLF, FCDLFI, FCDLHORP or FCDLHORPI

Must be False where, transaction category is RPRT, PLEQ, OTPRTY, ASIP, IOSH, AOSH, IEIOOS, AQIOS, ASSD, ASSL, ASSBC, ASSOPR or SBER

Is this transaction covered by an exclusion list category?

LCMSF48

True or False

Mandatory question

Must be False where transaction category is RUIP, ORSR, LF, RRP, HLPE, LHORP, CCIRS, CDCSFFO, FFIRS, OIRD, CDS, CDCS, AS, OD, SBER, IDF, ODF, IDSEC, ODSEC, GILDI, GIOKL, IN, REIN, OFD, RPRT, PLEQ OTPRTY, FCDSTTS, FCDPTTS, FCDAPS, FCDAAS, FCDRRP, FCDRRPI, FCDHLP, FCDHLPE, FCDSBER, FCDSBERI, FCDRUIP, FCDRUIPI, FCDORSR, FCDORSRI, FCDLF, FCDLFI, FCDLHORP or FCDLHORPI

What exclusion list category applies to this transaction?

LCMSF49

Exclusion list category code

Applicable only if LCMSF48 is True

See Local file instructions 2025 for which exclusion list category codes may be applicable for the relevant transaction category

See Appendix E

Transaction comments

LCMSF222

Text

Maximum of 4,096 characters

When transaction category is OS, ORIRPD, OD, OKDI or OFD then a short description of the kind of 'other' transaction must be provided at the Transaction Comments

Local file – Part B

This section is required if you have selected that you will be providing the Local file – Part B as part of this submission at LCMSF119.

For more information on providing IRP agreements in the Local file – Part B, see Local file – Part B: Guidance on providing International Related Party agreements.

Table 15: Local file – Part B

Question

Question ID

Valid values

Comments

Transaction identifier

LCMSF50

Number

Mandatory question

Incrementing number for each transaction that is used to link Part A and Part B

Which transfer pricing/capital asset pricing methodology has the IRP relied upon for this transaction?

LCMSF51

TP method or CAP method

Mandatory question

See Appendix C

Is the reporting entity unable to obtain the transfer pricing methodology the IRP relied upon for this transaction (from the IRP)?

LCMSF130

True or False

Required if LCMSF51 is 'Unknown (transfer pricing method)' or 'Unknown (capital asset pricing method)'

Is there a written agreement or other relevant documentation evidencing the terms of the agreement covering this transaction (as reported in Part A)?

LCMSF52

True or False

Mandatory question

If False, go to LCMSF106

Is the reporting entity unable to obtain from any of the related counterparties, the written agreement or other relevant documentation evidencing the terms of the agreement covering the transaction (as reported at Part A)?

LCMSF64

True or False

Required if LCMSF52 is True

If True, go to LCMSF106

Other transaction IDs covered by the agreement

LCMSF224

Number

Provide the transaction ID of other transactions (reported in Part A) that are covered by this agreement

Has this written agreement been previously provided to the ATO?

LCMSF53

True or False

Required if LCMSF52 is True and LCMSF64 is False

If False, go to LCMSF89

Did you provide the written agreement documentation for this transaction/RAS as part of your local file lodgment for a previous reporting period?

LCMSF239

True or False

Required if LCMSF53 is True

Title of the agreement(s) previously provided to the ATO

LCMSF54

Filename(s) of attachment(s), including extension

Required if LCMSF53 is True

At least one filename must be provided

See Attachments

Year agreement(s) was previously provided to the ATO?

LCMSF90

YYYY

Required if LCMSF53 is True

Confirm that you have attached the agreement(s) for this transaction

LCMSF89

True or False

Must be True if LCMSF53 is False

Filename(s) of IRP agreement(s)

LCMSF225

Filename(s) of attachment(s), including extension

Required if LCMSF89 is True

At least one filename must be provided

See Attachments

Since providing the written agreement to the ATO, has the agreement been amended?

LCMSF91

True or False

Required if LCMSF53 is True

If False, go to LCMSF106

Have the amended agreements or agreements incorporating the amendments been provided to the ATO?

LCMSF92

True or False

Required if LCMSF91 is True

Did you provide the amendment agreements or the amended agreement incorporating all the amendments for this transaction/RAS as part of your local file lodgment for a previous reporting period?

LCMSF240

True or False

Required if LCMSF92 is True

What is the title of the amendment agreements or agreement incorporating the amendments previously provided to the ATO?

LCMSF132

Filename(s) of attachment(s), including extension

Required if LCMSF92 is True

At least one filename must be provided

See Attachments

What is the year in which the amendment agreements or agreements incorporating the amendments was previously provided to the ATO?

LCMSF133

YYYY

Required if LCMSF92 is True

Please confirm that you have attached the amendments for previously provided agreements for this transaction

LCMSF131

True or False

Must be True if LCMSF92 is False

Filename(s) of the amended agreement(s)

LCMSF226

Filename(s) of attachment(s), including extension

Required if LCMSF131 is True

At least one filename must be provided

See Attachments

Are there APAs/rulings provided by other jurisdictions for this transaction?

LCMSF106

True or False

Mandatory question

If False, skip this section

Which other Transaction IDs does that APA/ruling cover?

LCMSF228

Number

Provide the transaction ID of other transactions (reported in Part A) that are covered by this APA or ruling

Has the reporting entity previously provided these APAs/rulings to the ATO?

LCMSF134

True or False

Required if LCMSF106 is True

If False, go to LCMSF135

Did you provide the APAs/rulings for this transaction/RAS as part of your local file lodgment for a previous reporting period?

LCMSF241

True or False

Required if LCMSF134 is True

What is the filename of the APAs/ Rulings previously provided to the ATO?

LCMSF238

Filename(s) of attachment(s), including extension

Required if LCMSF134 is True

At least one filename must be provided

See Attachments

What is the year in which the reporting entity previously provided these APAs/rulings?

LCMSF136

YYYY

Required if LCMSF134 is True

Please confirm that you have attached the relevant APAs/rulings for this transaction

LCMSF135

True or False

Must be True if LCMSF134 is False

Filename(s) of the APAs /rulings

LCMSF229

Filename(s) of attachment(s), including extension

Required if LCMSF135 is True

At least one filename must be provided

See Attachments

Intermediary

Intermediary information

This section is only required if the form is submitted by an intermediary (for example, a tax agent) on behalf of the reporting entity.

Table 16: Intermediary information

Question

Question ID

Valid values

Comments

Intermediary ABN

LCMSF2

ABN

Must be a valid ABN

Intermediary name

LCMSF3

Name of the intermediary

Maximum of 200 characters

Intermediary email

LCMSF4

Email address

Maximum of 200 characters

Must be a valid email address

Intermediary phone

LCMSF5

Mobile or landline

Maximum of 16 characters

Tax agent number (TAN)

LCMSF6

TAN

Must be a valid TAN

Intermediary declaration

Table 17: Intermediary declaration

Question

Question ID

Valid values

Comments

Intermediary declaration statement accepted indicator

LCMSF58

True or False

I declare that:

  • this document has been prepared in accordance with information provided by the reporting entity
  • the reporting entity has given me a declaration stating that the information provided to me for the preparation of this document is true and correct

The reporting entity has authorised me as agent to give this document to the Commissioner of Taxation on its behalf.

Intermediary declaration signature date

LCMSF59

YYYY–MM–DD

The actual date on which the declaration is signed by the intermediary

Intermediary declaration signatory identifier

LCMSF60

A user login, a full name or an email address

Maximum of 200 characters

 

 











































QC103618