The Australian Taxation Office (ATO) released guidance on providing international related-party agreements (IRPA) as part of Part B of the local file for country-by-country reporting (CbCR), on 3 March 2017. The taxpayer is required to provide copies of IRPA in Part B of the local file for all transactions shown in Part A of the file, unless the transaction is covered by one of the eight categories on the Exclusions List.
The list covers transactions that are considered to not materially affect the application of the Australian transfer pricing rules, and include transactions eligible for simplified transfer pricing (TP) record-keeping, low-value or low-risk service agreements, employee secondment reimbursements, issue of ordinary shares, and etc.
