Australian transfer pricing data

Australian tax data
Written By Lewis McLeod

International related party transactions

International related party dealings (IRPD’s) are commercial or financial transactions between Australian businesses or investment entities and their overseas related parties (for example overseas parent companies or subsidiaries of Australian companies). Like most developed countries, these transactions can be subject to Australia’s transfer pricing rules and require various additional disclosures in the Australian entity’s annual tax return and other tax filings.

Data sources

The Australian Tax Office (ATO) publishes their dataset International related party dealings statistics 2021–22 which provides key statistics and data sourced from the following annual Australian tax filing requirements for the 2021–22 and earlier income years.

(1) Annual tax return - International Dealings Schedule (IDS)

Companies, partnerships, trusts with international related party transactions greater than $2 million are required to lodge an IDS. For small business entities there is a higher threshold of the lesser of $5 million or 50% of aggregated turnover. International related party transactions are disclosed by transaction type in the aggregate at Section A of the IDS.

(2) Country-by-country reporting - Local file – part A (LFPA)

Country-by-country (CBC) reporting entities are required to lodge country-by-country (CBC) reporting statements, which include a document called the “local file”.

The local file includes part A (LFPA), which collects IRPD data for individual transactions, at a more detailed level than the aggregated IRPD data in the IDS.

Where statistics are sourced from the LFPA, IRPD data is aggregated to the taxpayer level, to align with IDS reporting.


Dashboard: Transactions and countries

We have analysed the latest ATO dataset for the 2016-2022 financial years to present a more dynamic and interactive tool for users to understand how Australian businesses transact with their global related parties. Our report is split into two sections as follows:

Click on the full screen mode below on your desktop for the best Power Bi report experience…

Report # 1 - Transaction values by transaction type including count of the number of Australian entities with those international related party transactions.

As the highest transaction values for all years are revenue / expenses from the sale/purchase of tangible property (e.g. inventory), we have split the list of transactions between intangible items (e.g. service fees and financing transactions) vs tangible property / capital transactions (such as debt factoring and asset purchases and disposals). This allows the user to compare the transaction type values across the dataset.

Report #2 - Transaction values by country showing the relative size of the annual revenue and expense transactions with related parties in each country, including the count of the number of Australian entities with those transactions.

The countries listed in the dataset refers to where the non-resident counterparty to the international related party transaction with Australia is located (i.e. tax residency or location of a permanent establishment).

Australia, itself, is listed in this report because ‘reportable international related party transactions’ for the purposes of the Australian tax filings used for the ATO dataset includes related party dealings with an Australian resident entity in the course of the entity’s overseas branch operations.

More information

Thank you for taking the time to view our report. Please reach out to us if you would like to discuss this in more detail.

Lewis McLeod
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