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Australia Local File Guidance on Provision of International Related Party Agreements in Local File — Orbitax Tax News & Alerts

On 3 March 2017, the Australian Taxation Office published guidance on providing International Related Party (IRP) agreements as part of the new Local file requirements. Under Australia's requirements, the Local file consists of two parts: Part A, which includes details of the related party transactions; and Part B, which includes the transfer pricing methods used, copies of agreements, and copies of APAs ({News-2016-06-14/A/2- previous coverage}). The guidance covers details for providing IRP agreements as part of the Local file, including:

  • General principles on providing IRP agreements;
  • What comprises written agreements in various scenarios;
  • Relevant Agreement Series (RAS - repeating series of transactions or dealings on revenue account);
  • The principles for determining a material representative agreement in selecting the agreement documentation provided at Part B for a RAS; and
  • Special rules that apply to offshore banking units (OBUs) and banks.

Click the following link for Local file – Part B: Guidance on providing International Related Party agreements.