Australia Finalises Rules On Reporting Foreign Exchange Gains And Losses In Local File

Regular short term deferred foreign currency payment arrangements

• the deferred payment arrangements are not irregular; and
• the deferred payment arrangements do not involve payment or other satisfaction of the amounts more than 12 months after the date the amounts become due.

• The following codes are shown for the relevant IRP transaction/RAS*:
  • Code indicating regular/short term foreign currency deferred payment arrangements;
  • Code indicating the relevant foreign currency, for example USD.
• No requirement to show the amount of FX gains returned or FX losses deducted for the relevant IRP transaction/RAS in Part A of the Local File

Irregular or longer term deferred foreign currency payment arrangements

Either:

• irregular; or
• involve payment or other satisfaction of the relevant amounts more than 12 months after the date the amounts become due

• The following codes are shown for the relevant IRP transaction/RAS:
  • Code indicating irregular or longer term foreign currency deferred payment arrangements or,
  • Code indicating the relevant foreign currency.
• Require to show the amount of the FX gains returned or FX losses deducted for the relevant IRP transaction/RAS for Australian income tax is shown

FX gains and losses in other scenarios

Any IRP transaction/RAS in the following Transaction categories or Transaction category groupings:

• IRPD debt interests (including ordinary loans and borrowings);
• IRP derivatives transactions;
• IRPD debt factoring or debt securitisation;
• Other kinds of IRPDs of a financial nature;
• IRPD Royalties (including Rights to use IP and Other rights to use, supply orreceive where consideration is royalty under section 6(1)), IRPD Licence feesand IRPD Lease or hire of other property or rights) ;
• Other revenue non-financial IRPDs – including IRPD cost contributionarrangements;
• IRPDs involving disposal or acquisition of tangible property of a non-revenue(capital) nature;
• IRPDs involving disposal or acquisition of intangible property of a non-revenue(capital) nature.

• The following codeis shown for the relevant IRP transaction/RAS:
  • Code indicating the relevant foreign currency.
• Require to show the amount of any FX gains returned and FX losses deducted for the IRP transaction/RAS for Australian income tax.