The Australian Taxation Office (ATO) issued guidance for the local and master file requirements for 2024 on 15 July, 2024. This guidance applies to reporting periods commencing from 1 January 2023.
This guidance includes the Local file instructions 2024 and the Local file/master file 2024.
Local file instructions 2024
These instructions should be used when completing the 2024 local file as part of the country-by-country reporting obligations. It includes the following sections:
The instructions to help you complete your local file for your country-by-country (CBC) reporting obligations. While these instructions are not a guide to income tax law, you can use them to help you complete your local file when meeting this part of your country-by-country (CBC) reporting obligations. These instructions apply to the local file for 2024. This relates to reporting periods starting from 1 January 2023.
This section includes definitions of international related parties and international related party dealings. International related parties are persons who are not dealing wholly independently with one another in their commercial or financial relations, and whose dealings or relations can be subject to either Subdivision 815-B of the Income Tax Assessment Act 1997 (ITAA 1997).
It includes guidance on how to complete the short form local file.
It includes how to complete Part A of the local file.
IRPD in tangible property of a revenue nature
It includes on how to report IRPD in tangible property of a revenue nature.
It explains how to report IRPD service arrangements.
It explains how to report IRPD use rights.
IRPD share-based employment remuneration
This section explains how to report IRPD share-based employment remuneration.
This section explains what a derivative is and how to report IRPD derivative transactions.
IRPD debt interests (including ordinary loans and borrowings)
This section explains how to report IRPD debt interests.
IRPD debt factoring or debt securitisation
This section explains how to report IRPD debt factoring or debt securitisation.
Other kinds of IRPDs of a financial nature
This section explains how to report other kinds of IRPDs of a financial nature, and how ‘financial nature’ is defined. For reporting of IRPDs of a financial nature, the term ‘financial nature’ refers to dealings in financial instruments that would qualify as financial assets or financial liabilities under relevant Australian accounting standards or comparable foreign accounting standards.
IRPDs involving disposal or acquisition of tangible property of a non-revenue (capital) nature
This section explains how to report IRPD involving disposal or acquisition of tangible property of a non-revenue (capital) nature.
This section explains how to report IRPD involving disposal or acquisition of intangible property or rights of a non-revenue (capital) nature.
IRPD foreign currency deferred payment arrangements
This section explains how to report IRPD foreign currency deferred payment arrangements.
This section explains how to complete Part B of the local file.
Local file/master file 2024
This guidance provides a detailed description of the design and requirements of the local file and master file for 2024 and includes the following sections:
This section outlines the two tiers that the local file is composed of and the local file information requirements. The 2024 local file, applies to reporting periods for income tax years starting on or after 1 January 2023.
This section provides an explanation of what the master file section indicates and where to find more information about submitting the master file. A master file may be submitted together with a local file or CbC report notification, or as a separate lodgment.
This section explains what the CbC report notification indicates. A CBC report notification may be submitted with a master file or local file (or part thereof) or as a stand-alone lodgment.
