Appendixes

Last updated 15 February 2022

All foreign countries or jurisdictions not listed in the tables of listed countries and specified countries or jurisdictions are included in the other unlisted country or jurisdiction category.

Appendix 1: Specified countries or jurisdictions names and codes

A – C

D – M

N – Z

A – C Specified countries or jurisdictions names and codes
Code	Specified country or jurisdiction
AND	Andorra
AIA	Anguilla
ATG	Antigua and Barbuda
ABW	Aruba
BRB	Barbados
BHS	Bahamas
BHR	Bahrain
BLZ	Belize
BMU	Bermuda
VGB	British Virgin Islands
CYM	Cayman Islands
COK	Cook Islands
CUW	Curacao
CYP	Cyprus

D – M: Specified countries or jurisdictions names and codes
Code	Specified country or jurisdiction
DMA	Dominica
GIB	Gibraltar
GRD	Grenada
GGY	Guernsey
HKG	Hong Kong
IRL	Ireland
IMN	Isle of Man
JEY	Jersey
LBR	Liberia
LIE	Liechtenstein
LUX	Luxembourg
MHL	Marshall Islands
MUS	Mauritius
MCO	Monaco
MSR	Montserrat

N – Z: Specified countries or jurisdictions names and codes
Code	Specified country or jurisdiction
NRU	Nauru
NLD	Netherlands
NIU	Niue
PAN	Panama
KNA	Saint Kitts and Nevis
LCA	Saint Lucia
SXM	Sint Maarten (Dutch Part)
VCT	Saint Vincent & the Grenadines
WSM	Samoa
SMR	San Marino
SYC	Seychelles
SGP	Singapore
CHE	Switzerland
TCA	Turks and Caicos Islands
VIR	US Virgin Islands
VUT	Vanuatu

Appendix 2: Foreign and other jurisdiction names and codes

A – C

D – M

N – Z

A – C: Foreign countries or jurisdictions names and codes
Code	Country or jurisdiction
AFG	Afghanistan
ALA	Aland Islands
ALB	Albania
DZA	Algeria
ASM	American Samoa
AND	Andorra
AGO	Angola
AIA	Anguilla
ATA	Antarctica
ATG	Antigua and Barbuda
ARG	Argentina
ARM	Armenia
ABW	Aruba
AUT	Austria
AZE	Azerbaijan
BHS	Bahamas
BHR	Bahrain
BGD	Bangladesh
BRB	Barbados
BLR	Belarus
BEL	Belgium
BLZ	Belize
BEN	Benin
BMU	Bermuda
BTN	Bhutan
BOL	Bolivia
BES	Bonaire, Saint Eustatius and Saba Islands
BIH	Bosnia and Herzegovina
BWA	Botswana
BVT	Bouvet Island
BRA	Brazil
IOT	British Indian Ocean Territory
VGB	British Virgin Islands
BRN	Brunei Darussalam
BGR	Bulgaria
BFA	Burkina Faso
BDI	Burundi
KHM	Cambodia
CMR	Cameroon
CAN	Canada
CPV	Cabo Verde
CYM	Cayman Islands
CAF	Central African Republic
TCD	Chad
CHL	Chile
CHN	China
CXR	Christmas Island
CCK	Cocos (Keeling) Islands
COL	Colombia
COM	Comoros
COD	Congo, Democratic Republic of (was Zaire)
COG	Congo, Republic of
COK	Cook Islands
CRI	Costa Rica
CIV	Côte d'Ivoire (Ivory Coast)
HRV	Croatia (Hrvatska)
CUB	Cuba
CUW	Curacao
CYP	Cyprus
CZE	Czech Republic

D – M: Foreign countries or jurisdictions names and codes

Code	Country or jurisdiction
DNK	Denmark
DJI	Djibouti
DMA	Dominica
DOM	Dominican Republic
TLS	East Timor (Timor Leste)
ECU	Ecuador
EGY	Egypt
SLV	El Salvador
GNQ	Equatorial Guinea
ERI	Eritrea
EST	Estonia
SWZ	Eswatini (Swaziland)
ETH	Ethiopia
FLK	Falkland Islands (Malvinas)
FRO	Faroe Islands
FJI	Fiji
FIN	Finland
FRA	France
GUF	French Guiana
PYF	French Polynesia
ATF	French Southern Territories
GAB	Gabon
GMB	Gambia
GEO	Georgia
DEU	Germany
GHA	Ghana
GIB	Gibraltar
GRC	Greece
GRL	Greenland
GRD	Grenada
GLP	Guadeloupe
GUM	Guam
GTM	Guatemala
GGY	Guernsey
GIN	Guinea
GNB	Guinea-Bissau
GUY	Guyana
HTI	Haiti
HMD	Heard and McDonald Islands
VAT	Holy See (Vatican City State)
HND	Honduras
HKG	Hong Kong
HRV	Hrvatska (Croatia)
HUN	Hungary
ISL	Iceland
IND	India
IDN	Indonesia
IRN	Iran
IRQ	Iraq
IRL	Ireland
IMN	Isle of Man, The
ISR	Israel
ITA	Italy
CIV	Ivory Coast (Côte D'Ivoire)
JAM	Jamaica
JPN	Japan
JEY	Jersey
JOR	Jordan
KAZ	Kazakhstan
KEN	Kenya
KIR	Kiribati
PRK	Korea, Democratic People's Republic of (North Korea)
KOR	Korea, Republic of (South Korea)
KWT	Kuwait
KGZ	Kyrgyzstan
LAO	Laos
LVA	Latvia
LBN	Lebanon
LSO	Lesotho
LBR	Liberia
LBY	Libya
LIE	Liechtenstein
LTU	Lithuania
LUX	Luxembourg
MAC	Macau (Macao)
MKD	Macedonia, The Former Yugoslav Republic of
MDG	Madagascar
MWI	Malawi
MYS	Malaysia
MDV	Maldives
MLI	Mali
MLT	Malta
MHL	Marshall Islands
MTQ	Martinique
MRT	Mauritania
MUS	Mauritius
MYT	Mayotte
MEX	Mexico
FSM	Micronesia, Federated States of
MDA	Moldova
MCO	Monaco
MNG	Mongolia
MNE	Montenegro
MSR	Montserrat
MAR	Morocco
MOZ	Mozambique
MMR	Myanmar (Burma)

N – Z: Foreign countries or jurisdictions names and codes

Code	Country or jurisdiction
NAM	Namibia
NRU	Nauru
NPL	Nepal
NLD	Netherlands
NCL	New Caledonia
NZL	New Zealand
NIC	Nicaragua
NER	Niger
NGA	Nigeria
NIU	Niue
NFK	Norfolk Island
MNP	Northern Mariana Islands
PRK	North Korea
NOR	Norway
OMN	Oman
PAK	Pakistan
PLW	Palau
PSE	Palestinian Territories
PAN	Panama
PNG	Papua New Guinea
PRY	Paraguay
PER	Peru
PHL	Philippines
PCN	Pitcairn Island
POL	Poland
PRT	Portugal
PRI	Puerto Rico
QAT	Qatar
REU	Reunion
ROU	Romania
RUS	Russian Federation
RWA	Rwanda
BLM	Saint Barthélemy
SHN	Saint Helena
KNA	Saint Kitts and Nevis
LCA	Saint Lucia
MAF	Saint Martin (French Part)
SXM	Sint Maarten (Dutch Part)
SPM	Saint Pierre and Miquelon
VCT	Saint Vincent and The Grenadines
WSM	Samoa
SMR	San Marino
STP	Sao Tome and Principe
SAU	Saudi Arabia
SEN	Senegal
SRB	Serbia
SYC	Seychelles
SLE	Sierra Leone
SGP	Singapore
SVK	Slovakia (Slovak Republic)
SVN	Slovenia
SLB	Solomon Islands
SOM	Somalia
ZAF	South Africa
SGS	South Georgia and the South Sandwich Islands
KOR	South Korea
SSD	South Sudan
ESP	Spain
LKA	Sri Lanka
SDN	Sudan
SUR	Suriname
SJM	Svalbard and Jan Mayen Islands
SWE	Sweden
CHE	Switzerland
SYR	Syria
TWN	Taiwan
TJK	Tajikistan
TZA	Tanzania
THA	Thailand
TLS	Timor-Leste (East Timor)
TGO	Togo
TKL	Tokelau
TON	Tonga
TTO	Trinidad and Tobago
TUN	Tunisia
TUR	Turkey
TKM	Turkmenistan
TCA	Turks and Caicos Islands
TUV	Tuvalu
UGA	Uganda
UKR	Ukraine
ARE	United Arab Emirates
GBR	United Kingdom
USA	United States
UMI	United States Minor Outlying Islands
VIR	United States Virgin Islands
URY	Uruguay
UZB	Uzbekistan
VUT	Vanuatu
VAT	Vatican City State (Holy See)
VEN	Venezuela
VNM	Vietnam
WLF	Wallis and Futuna Islands
ESH	Western Sahara
YEM	Yemen
ZMB	Zambia
ZWE	Zimbabwe

Appendix 3: Listed country names and codes

Listed country names and codes
Code	Listed country
CAN	Canada
FRA	France
DEU	Germany
JPN	Japan
NZL	New Zealand
GBR	United Kingdom of Great Britain and Northern Ireland
USA	United States of America

Appendix 4: Activity codes

Activity codes
Activity code	Activity code description
1	Administrative services Activities that relate to an entity's operations but excluding activities relating to financing and production. These activities include: management services back office services administrative services associated with recharge amounts accounting services IT support services human Resources legal accounting.
2	Advisory services Activities involving the provision and receipt of professional advice where a fee is paid for the advice, including: consultancy activities investment advice legal advice.
3	Asset management Activities associated with the management of assets, funds or investments. This will be undertaken on a discretionary basis in accordance with an investment strategy, with the entity responsible for: acquiring, monitoring, managing and disposing of traditional and alternate financial products held by the taxpayer or a related party assessing, monitoring and managing the market risks associated with holding these financial products.
4	Borrowing and lending Activities involving the generation of internal and external funding.
5	Brokerage Activities involving the mediation between a buyer and a seller, occurring in a range of products, including: mortgages, where brokers act as intermediaries to sell mortgage loans on behalf of individuals or businesses commodities, where brokers execute orders to buy or sell commodity contracts on behalf of clients investment, where brokers act as intermediaries between investment buyers and sellers.
6	Cash & trade services Activities involving the facilitation of fund transfers and the exchange of goods and services, including: cash management systems (payment processing systems) foreign exchange clearing services trade settlements letters of credit (trade, insurance and export).
7	Construction All construction activities including residential and commercial construction and the construction of utilities and infrastructure.
8	Custody and transaction clearing services Custody is all activities that are associated with the safekeeping of securities for customers, also includes the collection of dividends, interest and proceeds from securities sales. Transaction clearing are all activities associated with the management of post-trading, pre-settlement credit exposures, to ensure that trades are settled in accordance with market rules, including: reporting and monitoring risk margining netting of trades to single positions.
9	Derivatives Activities undertaken in respect of derivatives (a financial instrument derived from some other asset, index, event, value or condition). The overall derivatives market has five major classes of underlying asset: interest rate derivatives (for example, interest rate swaps or options) foreign exchange derivative (for example, currency swaps or options) credit derivatives (for example, credit default swaps or options) equity derivatives (for example, equity swaps or warrants) commodity derivatives (for example, commodity swaps or gold options).
10	Distribution and sale of goods Goods purchased by a distributor from an international related party.
11	Financing activities Activities involving dealings in financial instruments that would qualify as financial assets or financial liabilities under relevant Australian accounting standards or comparable foreign accounting standards but excludes financial instruments that would meet the definition of a derivative. At the time of this publication, the two key Australian accounting standards relevant to this question include: AASB 132 Financial Instruments: Presentation AASB 139 Financial Instruments: Recognition and Measurement. The relevant amounts may be reported in the financial statements as revenue and gains or expenses and losses, depending on the accounting treatment of your relevant financial assets and financial liabilities (this includes amounts relating to hedging items that are classified in the financial statements as financial assets or financial liabilities). Therefore, for the purposes of this activity code: expenditure and losses are interchangeable revenue and gains are interchangeable.
12	Guarantees Activities associated with contracts under which a party agrees to perform an obligation or discharge a liability of another entity should that entity fail to do so.
13	Insurance and reinsurance Insurance and reinsurance activities include general insurance, life insurance and health insurance.
14	Leasing Activities that relate to agreement between two parties under which one is granted the right to use the property of the other for a specified period of time in return for a series of payments by the user to the owner.
15	Licensing or transfer of intellectual property Activities involving an intellectual property rights owner (licensor) and another entity which is given authorisation to use these rights (licensee) in exchange for an agreed payment (fee or royalty). This includes activities involving: technology license agreements trademark licensing agreements copyright license agreements trademark license agreements franchise agreements sales or purchase of IP.
16	Logistics Activities associated with the managing of a commercial organisation’s supply chain that supports the sourcing, timing and movement of goods and services, including: shipping transport storage procurement and sourcing freight scheduling.
17	Manufacturing and sale of goods Activities involved in the sale of goods created by a manufacturing process (excluding agriculture).
18	Media, telecommunications and information services With regard to media and information services, activities associated with the creation, collation, dissemination and distribution of content via: television radio newspapers, journals or magazines (hardcopy and equivalent electronic versions) books (both hardcopy and equivalent electronic versions) CD and DVD internet other information and communication channels. With relation to Telecommunications, activities associated with the operation, management, maintenance and sale of access to telecommunications infrastructure and networks including: telephony fax or data digital cable and satellite television internet.
19	Primary production/extraction and sale of goods Activities involved in the sale of physical products that have resulted from: the growing of crops, raising of animals, growing and harvesting of timber the extraction of naturally occurring mineral solids, such as coal and ores; liquid minerals, such as crude petroleum; and gases, such as natural gas.
20	Purchase and distribution of goods Goods sold by a distributor to an international related party.
21	Purchase and manufacture of goods Activities associated with the purchase of goods to be used in a manufacturing process (excluding agriculture).
22	Receipt/payment of dividends and distributions from trusts and partnerships
23	Retail trade Activities associated with the retail trade of all goods classifications to end customers through a shopfront or e-commerce website.
24	Sales and marketing services Sales: commission and amounts received or paid in respect of the provision of services to facilitate the sale of goods or services amounts received or paid in respect of transaction, investment and information services carried out on behalf of customers relating to the customer’s securities, financial assets, financial liabilities, portfolios and other assets. Marketing: activities that involve acquiring new customers or businesses and maintaining a relationship with them, including advertising brand promotion sales strategies customer support services.
25	Securitisation services Activities involving the packaging of an income by the party entitled to it and the subsequent sale of such income stream to investors.
26	Software and information technology services Activities involved in the support and maintenance of software and technology used by the taxpayer. Activities relating to the ownership of the software and technology are excluded, such as leasing and rental fees.
27	Superannuation Activities associated with providing, funding or offering investment strategies for financial security upon retirement.
28	Technical services Activities involving: engineering project management R&D exploration.
29	Toll manufacturing services Activities involved with the provision of manufacturing services for a fee or price per unit payment, where the manufacturing entity does not take legal title to the inventory or finished goods.
30	Treasury related services Activities involved in the managing of the taxpayer's financial operations, including: transaction, investment and information services relating to securities, financial assets, financial liabilities, portfolios and other assets held by yourself or an international related party risk management systems development and review the management of currencies and cash flows complex strategies, policies and procedures relating to the taxpayer finance.
31	Underwriting services Activities involves measuring risk exposure and determining the premium that needs to be charged to insure that risk, including: securities underwriting (underwriter assumes risk in bringing the issue to market by guaranteeing the issuer will receive a certain price when the offering is sold to investors) bank underwriting (underwriting is the detailed credit analysis preceding the granting of a loan, based on credit information furnished by the borrower). Insurance underwriting should be reported under activity code 13 – insurance and reinsurance.
32	Utilities and infrastructure Activities associated with the operation and management of utilities (for example, electricity, gas, water, sewerage) and infrastructure (for example, roads, rail, airports, sea ports).
99	Other All other activities not listed above.

Appendix 5: Main pricing methodologies

The arm's length pricing methodologies should be identified using the codes listed below.

Main pricing methodologies

Code	Arm's length pricing method
1	Apportionment of costs This pricing method apportions the costs associated with a controlled transaction among the associated enterprises. However, cases may arise where neither comparable dealings nor data are available to apply to traditional, or profit-based, methods. In these instances, application of an indirect method such as apportionment of costs on the basis of a formula may be applicable.
2	Apportionment of income This pricing method apportions the income associated with a controlled transaction among the associated enterprises. As with code 1, this method may be appropriate where there are neither comparable dealings nor data to apply the traditional, or profit-based, methods to the pricing problem.
3	Comparable uncontrolled price method This traditional transfer pricing method compares the price for property or services transferred in a controlled transaction, that is, with a related international party, to the price that is charged for comparable property or services under the same or similar circumstances in an uncontrolled transaction. Where it is possible to locate comparable uncontrolled transactions, the comparable uncontrolled price method is the most direct and reliable way to apply the arm's length principle. If there is any difference between the prices or the terms or nature of the controlled transaction and the uncontrolled transaction, this may indicate that the dealings of the associated enterprises are not arm's length. Note that intangible and intellectual property transactions present particular problems with regard to comparability, especially where such property is unique or specialised. If you use this method but the comparable uncontrolled price is adjusted to allow for particular circumstances of the controlled dealing, you should still record the adjusted price under this code.
4	Cost-contribution arrangement A cost-contribution arrangement is one where members of a multinational group act in concert for the benefit of each of the participants to: produce or provide goods, intangible property or services acquire these jointly from a third party agree to share the actual costs and risks undertaken. Each participant bears a fair share of the costs and is entitled to receive a fair share of rewards. The concept is akin to a joint venture or partnership. To be consistent with the arm's length principle, the contributors must be satisfied that they can obtain an acceptable rate of return within a timeframe that takes into account their financial and business circumstances. For more information, see Taxation Ruling TR 2004/1 - Income tax: international transfer pricing - cost contribution arrangements.
5	Cost-plus method This is a traditional transfer pricing methodology. The cost-plus method begins with the costs incurred by the supplier of property or services in a controlled transaction for property transferred or services provided to a related purchaser. An appropriate arm's length cost-plus mark-up is then added to this cost to make an appropriate profit in light of the functions performed and the market conditions. What is arrived at after adding the arm's length cost-plus mark-up to the above costs may be regarded as an arm's length price of the original controlled transaction. This method is probably most useful if: semi-finished goods that are subject to additional manufacturing or assembly are sold between related parties related parties have concluded joint facility agreements or long-term buy-and-supply arrangements the controlled transaction is the provision of services. This method is not suited for high value intangibles. Further analysis can be undertaken by reviewing the cost plus mark-up of the supplier in the controlled transaction. This is done by referencing the cost plus mark-up that the same supplier earns in comparable uncontrolled transactions. The cost plus mark-up that would have been earned in comparable transactions by an independent enterprise may serve as guidance. If a fixed percentage mark-up is applied to the relevant cost base without any benchmarking of that percentage against comparable independent dealings, it is not regarded as cost-plus method.
6	Fixed mark-up applied to cost This method determines the transfer price for a controlled transaction by applying a fixed percentage mark-up to a relevant cost base where the mark-up is not benchmarked against comparable independent dealings. The absence of benchmarking distinguishes this method from the cost-plus method discussed at code 5. The fixed mark-up applied to cost code should be used as described by TR 1999/1 Income tax: international transfer pricing for intra-group services has been utilised to set the pricing of intra group services.
7	Fixed percentage of resale price This pricing method determines the transfer price for a controlled transaction as a fixed percentage of the resale price, where the fixed percentage chosen is not benchmarked against the gross margins earned in comparable independent dealings. The absence of benchmarking distinguishes this method from the resale price method, code 10. The fixed percentage of resale price methodology code should be used as described by TR 1999/1 Income tax: international transfer pricing for intra-group services has been utilised to set the pricing of intra group services.
8	Marginal costing Marginal costing applies only the variable production costs to the costs of a product. This method is often used by companies and multinational enterprise groups for internal cost accounting and management control purposes. Its use in setting transfer prices on international dealings between associated enterprises for tax purposes is acceptable only if pricing on the basis of marginal costs represents an arm's length outcome for the transfer of goods or services into the particular market.
9	Profit split method This is a transactional profit methodology. The profit split method determines the appropriate pricing for transactions by: identifying the combined profit or loss from the dealings between the related parties splitting that combined profit or loss between the related parties. The split of profit or loss between the parties must be made on an economically valid basis that approximates the division of profits in an agreement made at arm's length.
10	Resale price method This traditional transfer pricing method may be appropriate where an enterprise sells a product to a related party who then resells that product to an independent third party. The resale price is reduced by the arm's length resale price margin and may then be regarded after adjustments for other costs associated with the original purchase of the product as an arm's length price of the original transfer of property between the related parties. Further analysis can be undertaken by reviewing the resale price margin of the reseller in the controlled transaction. This is done by referencing the resale price margin that the same reseller earns on items purchased and sold in comparable uncontrolled transactions. The resale price margin earned by an independent enterprise in comparable uncontrolled transactions may also provide guidance. Margins are usually measured at gross profit level, however a comparison undertaken at an intermediate level may be more accurate. A comparison at the net profit level falls under a different methodology - the transactional net margin method. The resale price margin will vary depending on the value added by the reseller. Variables such as functions performed, economic circumstances, assets employed, and risks undertaken should reflect higher margins.
11	Transactional net margin method This is a transactional profit methodology. The transactional net margin pricing method is based on comparisons made at the net profit level between the taxpayer and independent parties in relation to a comparable transaction or dealing. It examines the net profit margin relative to an appropriate base (for example, costs, sales or assets) that a taxpayer realises from a controlled transaction. Comparisons at the net profit level can be made on a single transaction or in relation to some aggregation of dealings between associated enterprises.
12	Transactional net margin method (whole-of-entity) The transactional net margin method is discussed at code 11. If after exercising commercial judgment you have decided to aggregate and test the arm’s length nature of multiple international related party dealings through the application of the transactional net margin method on a whole-of-entity basis, then use code 12 as the main pricing methodology. See Appendix 9 for when to use Transactional net margin method (whole-of-entity) methodology.
13	Other arm's length methods Use code 13 if your arm's length method is not represented by codes 1 to 12.
14	No transfer pricing method used Use code 14 if no principal transfer pricing method has been used.

Appendix 6: Derivative codes

The type of derivative should be identified using the codes listed below.

Derivative codes
Code	Type of derivative
1	Cross currency interest rate swap
2	Currency derivative (not cross currency interest rate swap) including currency swap, forward, future or option
3	Fixed for floating interest rate swap (not cross currency)
4	Other interest rate derivative (not cross currency)
5	Credit default swap
6	Commodity derivative including commodity swap, forward, future or option
7	Other asset swap
8	Other derivative

Appendix 7: Nature of item codes

Nature of item codes
Item code	Item code description
1	Company shares
2	Contract manufacturing
3	Contractual interests
4	Deposits/investment assets
5	Derivative portfolio
6	Insurance policies
7	Insurance recapitalisation
8	Intellectual property/intangibles
9	Interests in trust, partnership or other entity type
10	Loan assets
11	Loan liabilities
12	Marketing hubs
13	Real property
14	Shared services
15	Shipping
16	Trading activities
17	Other assets
18	Other functions
19	Other liabilities
20	Other risks

Where you believe that more than one item code may apply, use the most appropriate code.

The terms used in these codes should be interpreted in accordance with their ordinary meaning as used in the context of the industry to which the term relates.

Appendix 8: Transferor trust exemption codes

Transferor trust exemption codes
Code	Subsection/section
1	102AAT(1)(a)(i)(A) to (D) The transfer was: made to a non-resident discretionary trust an arm's length transaction undertaken in the ordinary course of business.
2	102AAT(1)(a)(i)(A) to (C) & (E) The transfer was: made to a non-resident discretionary trust an arm's length transaction not undertaken in the ordinary course of business neither the transferor nor its associates were in a position to control the trust (from the time of the transfer until the end of the transferor's current year of income).
3	102AAT(1)(a)(i)(A) to (C) & (F) The transfer was: made to a non-resident discretionary trust made either on or before 12 April 1989 neither the transferor nor its associates were in a position to control the trust (from 12 April 1989 until the transferor's current year of income). This exemption will not apply to transfers made in the last three income years.
4	102AAT(1)(a)(ii)(A) to (C) The transfer was: made to a non-resident non-discretionary trust made either on or after 12 April 1989 for a consideration equal to or greater than the arm's length amount.
5	102AAT(1)(a)(ii)(A), (B) & (D) The transfer was: made to a public unit trust (that is a non-resident trust estate) made either on or after 12 April 1989 for a consideration equal to or greater than the arm's length amount the sole purpose of the transaction was the arm's length acquisition of units in a public unit trust.
6	102AAZE De minimis exemption The transfer was made to a non-resident trust that is a resident of a listed country and the total of the attributable incomes of all non-resident trust estates is equal to or less than the lesser of either: $20,000 10% of the total of the net incomes of the trust estates.

Appendix 9: Percentage of dealings with documentation

Percentage of dealings with documentation' refers to the aggregate dollar amount of transactions reported at specific questions in the schedule for which you have relevant documentation expressed as a percentage of total dollar value of transactions reported at each specific question.

If your relevant related party dealings meet the conditions for one of the simplified record keeping options in PCG 2017/2, use code 7 for the dealings for which you decide to apply the simplified record-keeping option. The simplified record-keeping options available are:

Materiality – applicable revenue related dealings
Small taxpayers – applicable revenue related dealings
Distributors – applicable revenue related dealings
Low-value-adding intra-group services – applicable services related party dealings
Technical services – applicable technical services related party dealings
Low-level inbound loans – applicable inbound international related-party interest-bearing loans and associated expenses
Low-level outbound loans – applicable outbound international related-party interest-bearing loans and associated expenses

Transfer pricing documentation

For income years commencing on or after 29 June 2013, section 284-250 of Schedule 1 to the Taxation Administration Act 1953 provides that a particular way of applying Subdivision 815-B of the ITAA 1997 is not reasonably arguable for the purpose of applying Division 284 of Schedule 1 to the Taxation Administration Act 1953 (concerning administrative penalties) unless the entity meets the documentation requirements in section 284-255.

In order for the documentation requirements in section 284-255 to be met, certain factual matters set out in subsection 284-255(2) must be readily ascertained from records that meet the requirements of subsection 284-255(1).

TR 2014/8 sets out our views on the documentation requirements in section 284-255.

It is recommended at paragraphs 80 to 121 of TR 2014/8 that the following five key questions be considered when documenting your transfer pricing treatment in light of your facts and circumstances:

What are the actual conditions that are relevant to the matter?
What are the comparable circumstances relevant to identifying the arm's length conditions?
What are the particulars of the methods used to identify the arm's length conditions?
What are the arm's length conditions and is the transfer pricing treatment appropriate?
Have any material changes and updates been identified and documented?

If you meet the documentation requirements of Subdivision 284-E you may lessen the likelihood of the ATO conducting a transfer pricing review.

The selection of arm's length pricing methods for your related-party international dealings is discussed in TR 98/11.

Contemporaneous documentation

Documentation is contemporaneous if:

it is existing or brought into existence either
- at the time you are developing or implementing any arrangement that might raise transfer pricing issues
- when you are reviewing these arrangements prior to or at the time of the preparation of tax returns
the documentation records information relevant to determining the arm’s length conditions for the purpose of applying Division 815 of the ITAA 1997.

The documentation may be in the form of books, records, studies, budgets, plans and projections, analyses, conclusions and other material that record the information. It may be in electronic or written form.

The initial analysis of your international dealings for the purpose of determining the arm's length conditions for those dealings will have been carried out and documented at the time of engaging in the dealings. To review those international dealings before you prepare your tax returns is prudent business practice.

To determine the code for the percentage of your dealings with international related parties

At F items 5 to 13 and 17, write the relevant code from the table below for:

the percentage of your dealings with international related parties for which you have the relevant written documentation; it is not a requirement for the purposes of selecting the code that relevant written documentation meets all the requirements of Subdivision 284-E of Schedule 1 to the Taxation Administration Act 1953

code 7 for your dealings shown at items 5, 7, 8 or 11c for which you applied one of the simplified record-keeping options in PCG 2017/2.

If, after exercising commercial judgment, you have decided to aggregate and test multiple international related party dealings through the application of the transactional net margin method on a whole-of-entity basis, then do both of the following:

write code 12 at E to show transactional net margin method on a whole-of-entity as the main pricing methodology.
write the applicable code from the table below at label F to indicate the percentage of dealings with documentation for questions 5 to 13, and 17.

If, in exercising your commercial judgment you decide not to apply a whole of entity transactional net margin method analysis, you should test and document your international related party dealings separately and use one of the codes from the table below to show the percentage of the total of the dollar value for which you have documentation.

Percentage of total dollar value
Code	Percentage
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	Applied simplified record keeping option in PCG 2017/2

You may calculate the percentage on the basis of a reasonable estimate.

A statistical sample may be an appropriate method of calculating the relevant percentage, provided the sample selection and mathematical consideration are consistent with generally accepted statistical methods.

Keep your working papers if you have used a sampling process to make this estimate.

Appendix 10: Capital asset pricing methodologies

The capital asset pricing methodologies should be identified using the codes listed below.

Capital asset pricing methodologies
Code	Pricing method
1	Cost price
2	Directors valuation
3	Discounted cash flow
4	Independent valuation
5	Nil consideration
6	Quoted market price
7	Written-down value
8	Other methods

Cost price is the price the seller originally paid for the asset, including ancillary costs such as freight or handling.

Written-down value is a pricing method based on either the taxation 'adjustable value' or accounting residual value after depreciation has been allowed.

Discounted cash flow is a pricing method where the price of an asset is based on the discounted cash flow at the time of acquisition or disposal.

Director's valuation is a pricing method that is based on the directors' opinion of an asset's value, and not on any of the other methods listed in codes 1 to 8.

Independent valuation is a pricing method by which a suitably qualified person, acting at arm's length to both the buyer and seller, assesses the value of an asset.

Quoted market price is a price quoted on a public listed market, such as a public stock exchange, or commodities market.

Other methods are any other pricing method that is not mentioned in Appendix 5.

The above pricing methods may not provide an arm's length price under all circumstances. The above examples are not an exhaustive list.

Appendix 11: Capital value of a restructure

Use one of the following numeric codes to state the total of the dollar value of the restructure.

Total dollar value of restructure
Code	Range
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

The dollar amounts or values asked for in this question are all based on your existing accounting records. For these transactions we ask you to make a reasonable determination of the value and we do not expect you to obtain a formal valuation for this purpose. Keep your working papers if you have made a reasonable determination.

Appendix 12: Transaction types for which foreign exchange gain returned or foreign exchange loss deducted

Use the following transaction types for reporting of international related party dealings for which you have returned a foreign exchange gain or deducted a foreign exchange loss shown at item 11g.

The reference in the table to debt interests is to debt interests under Division 974 of the ITAA 1997. For more guidance on what is a debt interest under Division 974, see Guide to the debt and equity tests.

Transaction types for which foreign exchange gain returned or foreign exchange loss deducted
Code	Transaction type
1	IRP ordinary borrowings
2	IRP ordinary loans
3	IRP trade related liabilities
4	IRP trade related receivables
5	IRP other debt interests issued
6	IRP other debt interests acquired
7	Other IRP liabilities/payables
8	Other IRP assets/receivables

Appendix 13: Currency codes

Currency codes for foreign exchange gain returned or foreign exchange loss deducted, or main currency of the notional amount taken to be borrowed under section 160ZZZ
Currency code	Currency
USD	US Dollar
EUR	Euro
GBP	British Pound
JPY	Japanese Yen
CNY	Chinese Yuan Renminbi
KRW	South Korean Won
NZD	New Zealand Dollar
AED	UAE Dirham
HKD	Hong Kong Dollar
CAD	Canadian Dollar
MYR	Malaysian Ringgit
SEK	Swedish Krona
INR	Indian Rupee
CHF	Swiss Franc
SGD	Singapore Dollar
AUD	Australian Dollar, if functional currency under Subdivision 960-D is not AUD

Appendix 14: Type of hub

Hub type codes for offshore dealings subject to the schedules within PCG 2017/1
Code	Type of hub
MKT	Marketing hub
SHI	Shipping hub
SER	Services hub
SAL	Sales hub
NCP	Non-Core procurement hub
CPR	Core procurement hub

Appendix 15: Type of hybrid mismatch arrangement

Arrangement type codes for hybrid mismatches
Code	Hybrid mismatch arrangement
1	Hybrid financial instrument mismatch
2	Hybrid payer mismatch
3	Reverse hybrid mismatch
4	Branch hybrid mismatch
5	Deducting hybrid mismatch

Appendix 16: Reason for difference

Reason type codes for differences
Code	Exceptions
1	Timing deferral – term of the arrangement is less than three years
2	Reduced by dual inclusion income
3	Neutralised by another country’s foreign hybrid mismatch rules
4	Other

Appendix 17: Subdivision 832-J exceptions

Exception type codes related to subdivision 832-J
Code	Exceptions
1	Principal purpose test is not satisfied
2	CFC inclusion
3	Same or lesser rate of tax would have been paid by ultimate parent entity

QC58653