Information about functional currency rules, eligibility and the implications for tax accounting and reporting.

How to use this guide

The electronic version of this document is the only authorised version. Printed copies may be out of date.

Read this guide to find out more about the functional currency rules, including:

eligibility requirements
the implications for tax accounting and tax reporting.

You can use this guide if you are:

an Australian resident or a non-resident with a permanent establishment in Australia and both of the following apply
- you keep your accounts solely or predominantly in a particular foreign currency
- you wish to work out your taxable income (or tax loss) using that foreign currency – that is, using your ‘applicable functional currency’
a non-resident disposing of indirect interests in real property in Australia and the sole or predominant currency in which you keep your accounts at the time of disposal is a foreign currency. The application of functional currency rules is mandatory in this situation.

This guide does not cover income from overseas permanent establishments of resident taxpayers.

Functional currency translation rules

The functional currency translation rules are an exception to the core foreign currency translation rules.

Under the core foreign currency translation rules, amounts in a foreign currency must be translated into Australian dollars (A$). There are also rules about when and at what exchange rate a translation is to take place for a given type of transaction.

Under the functional currency rules, you can use a currency other than A$ as the unit of account to work out your taxable income or tax loss. The core foreign currency translation rules continue to apply to amounts and transactions not covered by the functional currency rules.

If you are an eligible taxpayer who keeps your accounts solely or predominantly in a particular foreign currency, you can choose to use that foreign currency as the unit of account to work out your taxable income or tax loss.

If you have made such a choice (that is, an effective functional currency choice), you do not translate transactions you undertake in either a foreign currency or in your applicable functional currency into A$. Rather, you translate only your net amount of taxable income or tax loss calculated in your applicable functional currency, into A$.

The core foreign currency translation rules are contained in section 960-50 of Subdivision 960-C of the Income Tax Assessment Act 1997 (ITAA 1997).

The functional currency translation rules are contained in section 960-80 of Subdivision 960-D of the ITAA 1997.

How the functional currency rules work

Once you choose to use a non-Australian dollar applicable functional currency, you must use that currency as the unit of account in your day-to-day tax accounting. After working out your taxable income or tax loss in the applicable functional currency, you must translate that amount into A$ to report on your tax return.

You must also carry out your instalment income calculations in your applicable functional currency and translate that amount into A$ for reporting purposes.

Eligibility to account in a functional currency

Only certain taxpayers can choose to work out their taxable income or tax loss using a non-Australian dollar applicable functional currency. This guide is relevant only if you are either of the following:

a resident who must prepare financial reports under section 292 of the Corporations Act 2001
a non-resident carrying on business through a permanent establishment in Australia.

Your applicable functional currency is the sole or predominant currency in which you keep your ‘accounts’ at the time you choose to use functional currency.

‘Accounts’ means ledgers, journals, statements of financial performance, profit and loss accounts, balance sheets and statements of financial position and includes statements, reports and notes attached to, or intended to be read, with such items.

Find out more in subsection 960-70(4) of the ITAA 1997.

The following taxpayers using a non-A$ applicable functional currency are not covered in this guide:

Australian residents carrying on business through overseas permanent establishments, using a non-A$ applicable functional currency to work out their taxable income or loss
attributable taxpayers in respect of controlled foreign companies (CFC) and transferor trusts, using a non-A$ applicable functional currency to work out the ‘attributable income’ of the CFC or transferor trust.

When to make a functional currency choice

The functional currency rules started to apply on 1 July 2003.

Ordinarily, if you choose to use a foreign currency as your applicable functional currency to work out your taxable income or tax loss, your choice will take effect after the end of the tax year during which you made it.

You must make your functional currency choice in writing.

In some circumstances, you can make your functional currency choice after the start of the tax year in which you intend it to take effect. This is referred to as a ‘backdated start up choice’. You must make a ‘backdated start up choice’ within 90 days of either of the following:

the start of the tax year, if your entity existed at that time
the day your entity came into existence, if it did not exist at the start of the tax year.

See details on:

when your choice takes effect in subsection 960-60(1) of the ITAA 1997
making your choice in writing in subsection 960-60(2) of the ITAA 1997
making a backdated start up choice in section 960-65 of the ITAA 1997.

Withdrawing an existing functional currency choice and substituting a new choice

You can withdraw your existing functional currency choice if the functional currency you are using ceases to be the sole or predominant currency in which you keep your ‘accounts’. Your functional currency choice withdrawal will take effect from the end of the tax year in which you withdraw it.

Your withdrawal:

cannot be backdated
must be made in writing
should be available as part of the business’s tax records.

After your previous functional currency choice is withdrawn, you can make a choice to use the new sole or predominant currency in which you keep your accounts to work out your taxable income or tax loss. You must make this choice in writing. If you don’t make a new functional currency choice, the core foreign currency translation rules will apply, which means that all amounts must be translated into A$.

See details on:

when your choice of currency ceases to be your main currency for accounts in subsection 960-90 of the ITAA 1997
when your functional currency choice withdrawal will take effect in items 1 and 2 of subsection 960-90(1) of the ITAA 1997
making a choice to use the new sole or predominant currency in which you keep your accounts in subsection 960-90(3) of the ITAA 1997.

Documenting your choice to use a non-Australian dollar applicable functional currency

When making your written choice to use a non-Australian dollar currency as your applicable functional currency, include all the following:

the name and tax file number of the entity making the choice
the use to which the functional currency is being put – for example, to work out taxable income or tax loss
the date the choice takes effect
the unit of account that the entity intends to use as its functional currency
the signature of the entity’s public officer and the date the written functional currency choice was signed.

You do not need to send your written functional currency choice to us. However, it should be available as part of your business’ tax records.

Non-functional currency amounts you receive or pay

All amounts included in working out your taxable income or tax loss must be in the applicable functional currency. This means you must translate all amounts you receive or pay in another currency, including A$ amounts, into the applicable functional currency.

The functional currency translation rules, including applicable exchange rates, follow the principles in the core foreign currency translation rules for translating foreign currency amounts to A$. This is covered in subsection 960-50(6) of Subdivision 960-C and also subsection 960-80(6) of Subdivision 960-D of the ITAA 1997.

However, the A$ is treated as a foreign currency while your applicable functional currency is not a foreign currency for the purposes of working out your taxable income or tax loss in the applicable functional currency. This is covered in subsection 960-80(1) of the ITAA 1997.

A foreign exchange (forex) realisation gain or loss may arise for certain amounts if there is a difference in prevailing exchange rates at the relevant times. For example, the exchange rate applicable at the time you incur an amount may be different from the exchange rate applicable when you pay it. In this situation, changes in the value of the A$ against the applicable functional currency can bring about a forex gain or loss – an example follows.

Example 1: trigger of foreign currency loss

Stellar Rex Incorporated (Stellar Rex), a USA company with a branch (permanent establishment) in Australia, chooses to account for their Australian branch’s taxable income in a functional currency. For Stellar Rex’s purposes, US dollars (US$) is the applicable functional currency and A$ is a foreign currency.

Stellar Rex contracts to purchase a depreciating asset from an Australian company in A$ as follows:

Year 1

Stellar Rex contracts to purchase the asset for A$10,000. Stellar Rex holds the asset from the date of contract.

At the contract time, A$1.00 = US$0.50.

Therefore, the cost of the asset in the applicable functional currency is US$5,000.

Year 2

Thirteen months after beginning to hold the asset, Stellar Rex pays A$10,000 for the asset.

At this time A$1.00 = US$0.55, so the A$10,000 Stellar Rex pays is equivalent to US$5,500.

A forex loss of US$500 is incurred by Stellar Rex when it pays A$10,000 for an asset in year 2. Since the payment was made over 12 months after acquiring the asset, the loss is not considered a short-term forex loss. Stellar Rex can deduct this loss when calculating the taxable income or tax loss of its Australian branch for year 2. The taxable income of the Australian branch is calculated in US dollars and converted to Australian dollars at the end of the tax year to determine the amount of income tax it owes.

Find out more about foreign currency translation (conversion) rules.

Pre-choice amounts

Special translation rules apply to amounts that are attributable to transactions or events that happened before your current functional currency choice took effect (‘pre-choice’ amounts). Pre-choice amounts that are relevant for working out your taxable income or tax loss for a year after your functional currency choice takes effect must be translated into your applicable functional currency in accordance with these special rules. This includes pre-choice amounts that are denominated in the same non-A$ currency as your applicable functional currency.

See details on:

examples of an amount in subsection 960-80(2) of the ITAA 1997
special translation rules in section 960-85 of the ITAA 1997.

If you haven’t previously made a functional currency choice, you should translate a relevant pre-choice amount as follows:

firstly, into A$ at the exchange rate applicable at the time of the transaction or event
secondly, into the applicable functional currency at the exchange rate at the time your functional currency choice took effect.

If you have previously made a choice to use a non-A$ currency as your applicable functional currency, you should translate a relevant pre-choice amount:

firstly, into the previous applicable functional currency at the exchange rate applicable at the time of the transaction or event
secondly, into the new applicable functional currency at the exchange rate at the time your new functional currency choice took effect.

Example 2: sale of assets acquired before making a functional currency choice

Fion Incorporated (FION), a non-resident corporation, operates through a permanent establishment in Australia. FION conducts most of its business in Yen (¥).

In the year ended 30 June (year 1) FION chooses to use ¥ as its applicable functional currency. The choice applies for the year commencing 1 July (year 2).

In the year ended 30 June (year 3) FION sells a tourist resort for ¥600 million, which it had purchased before year 1 for ¥500 million.

As FION’s applicable functional currency is ¥, the capital gain or capital loss on the disposal of the tourist resort will be calculated in ¥. However, FION had not made a choice to use ¥ as its applicable functional currency at the time it purchased the tourist resort – that is, it was still using A$ for tax purposes. Therefore, the ¥ cost of the resort is translated to A$ at the exchange rate prevailing at the time of the purchase. This A$ amount is then translated to ¥ at the exchange rate prevailing at the time FION’s choice to use ¥ as its applicable functional currency took effect.

For the purposes of this example, the exchange rates were:

A$1.00 = ¥68.50 at the time FION purchased the resort
A$1.00 = ¥62.00 at the time FION’s functional currency choice took effect.

This means the cost base for the purpose of calculating the capital gain or loss on the disposal of the tourist resort is:

(¥500,000,000 ÷ 68.50) × 62.00

= A$7,299,270 × 62.00

= ¥452,554,745

The capital gain calculated in FION’s applicable functional currency is:

Sale proceeds = ¥600,000,000
Less ¥452,554,745
Capital gain = ¥147,445,255.

End of example

Tax reporting and functional currency

The functional currency rules allow you to work out your taxable income or tax loss in your applicable functional currency. However, all tax reporting must still be expressed in A$. When reporting on your tax return or activity statement, work out the reported amounts in your applicable functional currency and then translate these amounts into A$.

For tax reporting purposes, when a translation is needed for label amounts (other than the taxable income amount), use the same translation rate as the taxable income translation rate. If you don’t have a taxable income amount in a given income year (that is, you have a tax loss), you should use the same rate you would have used to translate a taxable income amount into A$.

Amount type	Treatment
Amounts used in working out taxable income or tax loss in the applicable functional currency (FC).Note sections 6AB and 6AC of the Income Tax Assessment Act 1936 (ITAA 1936) with regard to foreign income and foreign tax and the ‘grossing-up’ of foreign income to include foreign tax paid.	Include the amount in the taxable income calculation in the FC before translating taxable income from the FC into A$.
Amounts used to work out taxable income or a tax loss that are in a foreign currency. For example:A$ amounts, including the ‘gross-up’ amount for a franked dividendamounts of foreign income, including the ‘gross-up’ amount for foreign tax paid in respect of that income.Section 6AC of the ITAA 1936 requires the amount of foreign income included in your assessable income to be ‘grossed-up’ to include any foreign tax you paid in relation to the foreign income. If you receive a franked dividend, section 207-20 of the ITAA 1997 requires you to ‘gross-up’ your assessable income by the amount of the franking credit – and also entitles you to a tax offset equal to the amount of the franking credit.	Translate into the FC using the applicable exchange rate for that amount.As ‘gross-up’ amounts contribute to the calculation of your taxable income or tax loss, you must translate them into the FC. Include the FC value in the taxable income calculation before translating taxable income from FC into A$ – see Example 3 and Example 4.
Carry-forward losses	Carry-forward losses are allowable deductions that reduce taxable income.Identify the carry forward loss amount in the FC from the previous income year.Include these amounts in the taxable income calculation in the FC before translating taxable income from FC into A$.When reporting the value of a tax loss, translate it from FC into A$.
Tax exempt amounts that reduce carry-forward losses	Tax exempt amounts that reduce carry-forward losses are translated into the FC generally upon being derived. They are then used to absorb the loss to the extent of their value.When reporting the value of a tax exempt amount, translate it into A$.
Foreign income tax offsets (FITO)Subsection 770-10(1) of the ITAA 1997 provides that you are entitled to a foreign income tax offset for foreign income tax you paid in respect of an amount of foreign income that is included in your assessable income in a year of income. (FITO in relation to the ‘attributable income’ of a CFC is not dealt with in this guide.)	The value of foreign income tax offset amounts is not used in working out taxable income, except for when calculating the ‘attributable income’ of a controlled foreign company (CFC) or transferor trust.The core foreign currency translation rules apply, and the value of foreign tax paid used to calculate foreign income tax offsets is translated into A$ when the foreign tax is paid – see Example 3.
Franking credits	A credit that arises in the franking account of an entity (a franking credit) is a tax offset.The amount of the tax offset you are entitled to as a result of receiving a franked dividend is not translated into your FC. Your tax offset amount will equal the A$ amount of the franking credit attached to the dividend you received before it was translated into functional currency.Add the A$ value of franking credits to your franking account without translation into FC – see Example 4.You must keep your franking account in A$.
Tax offsets and rebates	Tax offsets and rebates are not used to work out taxable income or a tax loss.The core foreign currency translation rules apply.If the amount is already in A$, then no translation takes place.If the amount is in a non-A$ currency, translate the amount into A$.Do not translate into FC first.
Values expressed in lawParagraph 960-80(2)(i) of the ITAA 1997 covers this.	Translate these amounts to FC at the applicable rate – see Example 5.

Example 3: foreign income tax offsets

In this example, you choose US dollars (US$) as your applicable functional currency.

Calculate your assessable income

¥115 = US$1.00 = A$2.00.

¥11,500 derived by you consisting of:

¥10,350 cash and ¥1,150 tax withheld in Japan.

To work out your taxable income, translate ¥11,500 into the US$ FC as follows:

¥11,500 = US$100 added to assessable income.

Taxable income in US$, including the amount you received in ¥, is translated into A$ at the end of the tax year. If, between the time you derived the income and tax year end, the relative value of the US$–A$ changes, this change will be reflected in the amount of A$ assessable income you will eventually bring to account. In this example, if at year end US$1.00 = A$1.75, then you will report the A$ assessable income you received from the ¥11,500 transaction as A$175.

Calculate your FITO

Translate the ¥1,150 tax withheld amount into A$ as follows:

¥1,150 = A$20

A$20 is used in calculating the amount of the foreign income tax offset, being the lesser of the amount of the foreign tax paid or the Australian tax payable on the foreign income.End of example

Example 4: franking credits

US$1.00 = A$2.00

XYZ Corporation (XYZ) is an Australian resident company, which chooses to use US$ as its applicable functional currency.

XYZ derives a fully franked dividend as follows:

A$70 cash

A$30 gross-up amount (franking credit value).

To find out more, refer to subsection 207-20(1) of the ITAA 1997.

Assessable income calculation

XYZ translates A$100 ($70 + $30) into US$ as follows:

A$100 × 0.5 = US$50.

At the end of the tax year, US$50 (and other taxable income values) are translated into A$ at regulation rate.

Franking account balance

Add A$30 to franking account balance. No translation takes place.End of example

Example 5: application of translation rule to a monetary limit

Exact Limited (Exact) has made a valid choice to use US$ as its applicable functional currency. In year 1, Exact purchases a car for US$40,000. At the time, the price is equivalent to A$72,700.

If the car limit under section 40-230 of the ITAA 1997 was A$60,000 in year 1, Exact would apply that provision by converting the limit to US$33,012. The first element of the US$ cost of a car is therefore reduced to that amount.End of example

Mandatory application of functional currency for indirect Australian real property interests

If:

you are a foreign resident
a CGT event happens in relation to a CGT asset that is an indirect Australian real property interest for you, and
at the time of the CGT event, the sole or predominant currency in which you keep your accounts is a currency other than Australian currency

you must use the applicable functional currency to work out the amount of any capital gain or capital loss. Subsection 960-61(2) of the ITAA 1997 covers this.

This requirement applies to CGT events that happen on or after 12 December 2006.

Capital gains and losses

There are 2 steps to work out a capital gain or capital loss.

Step 1 translate an amount that is not in the applicable functional currency into the applicable functional currency.

Step 2 translate the amount of any capital gain or capital loss into Australian currency.

See more details at table item 6 of subsection 960-80(1) of the ITAA 1997.

Exchange rates to apply

Different exchange rates apply to the translation of amounts that are elements in the calculation of capital gain or loss.

See more details at subsection 960-80(4) of the ITAA 1997.

The exchange rate to be used when translating amounts will be either the rate at the time the costs are incurred, or the rate at the time of the CGT event.

Exchange rate applicable at the time the costs are incurred

Amounts relating to the payments made and costs incurred that form part of the cost base of a CGT asset

These amounts are translated into your functional currency at the exchange rate applicable at the time the costs are incurred.

See details in:

table item 5 of subsection 960-50(6) of the ITAA 1997
TR 2007/5 Income tax: functional currency – when is an amount not in the ‘applicable functional currency’? paragraphs 110 and 153.

Exchange rate applicable at the time of the CGT event

Amounts which are relevant for working out the capital gain or capital loss (capital proceeds or market value of other property) on the happening of a CGT event

These amounts are translated into the applicable functional currency at the exchange rate applicable at the time of the CGT event.

See details in:

table item 5 in subsection 960-50(6) of the ITAA 1997
subsection 960-80(6) of ITAA 1997
TR 2007/5 Income tax: functional currency – when is an amount not in the ‘applicable functional currency’?

Amount of capital gain or capital loss calculated in the applicable functional currency

This amount is translated into the Australian currency at the exchange rate applicable at the time of CGT event.

See details in:

table item 5 in subsection 960-50(6) of the ITAA 1997
TR 2007/5 Income tax: functional currency – when is an amount not in the ‘applicable functional currency’?

Reporting during the year

Business activity statements

When completing a business activity statement (BAS):

calculate your instalment income in the applicable functional currency
translate your instalment income into Australian dollars at the appropriate rate
complete label T1 of the BAS accordingly.

Company tax return

The functional currency rules allow some taxpayers to choose to work out their taxable income or tax loss by using a non-A$ currency as their applicable functional currency (FC).

All amounts disclosed on the company tax return must be disclosed in A$.

When a label amount is accounted for in a non-A$ FC, that sum should be translated into A$ using the same functional currency translation rate (shown at label 8N Functional currency translation rate of the company tax return) used to translate the taxable income or tax loss figure.

The following amounts are always accounted for in A$, and not in the FC:

Label 7 J Franking credits
Label 7 C Australian franking credits from a New Zealand Company.

The following amounts do not need to be translated into A$ before completion of the return:

Label 7 R Tax losses deducted
Label 7 S Tax losses transferred in.

Tax losses are allowable deductions from taxable income. If you carry forward losses, you should account for and claim them in your FC. Report any losses used during the income year at label 7R by translating the value of the loss used into A$ at the FC translation rate.

As mentioned above, label 8N is where you show the exchange rate used to translate the FC taxable income figure (and many other figures on the company tax return) into A$.

At label 8N, show the translation rate the company used to translate the taxable income figure from the FC into A$. The translation rate is the amount the FC amount is divided by to get an equivalent amount of A$. That is, the number of non-A$ currency units that equal one A$ rounded to 4 significant figures – see Examples for labels 8N and 8O.

Label 80 – functional currency chosen

Label 80 is where you show your chosen FC using the 3-letter code from the international standard ISO 4217 – ‘Currency codes’. See the list of commonly used currencies and their ISO standard codes.

Labels 8N and 80 must be completed by:

Australian resident taxpayers who use FC to work out their taxable income or tax loss
foreign residents carrying on an activity or business at, or through, an Australian permanent establishment, who use FC to work out their taxable income or tax loss.

You should not complete labels 8N and 80 if you are an Australian resident taxpayer using FC only to work out the attributable income of a controlled foreign company (CFC) or transferor trust.

The following are examples of correctly completed labels 8N and 8O. The exchange rates used are from 26 September 2003.

Applicable FC	Label N	Label O
US Dollar	.6695	USD
Yen	77.18	JPY
New Zealand Dollar	1.1385	NZD
Won	785.8	KRW
Rupiah	5679	IDR

As mentioned previously, if you choose to use FC, you should account for the value of any carry-forward losses using that FC.

The value of those tax losses and net capital losses carried forward to later income years should be reported in A$ at ‘Losses information’ – labels 13U and 13V – on the company tax return.

Calculation statement

The calculation statement on the company tax return shows you how to work out the amount of tax payable or refundable. It starts with the ‘Taxable income’ figure at label A. This figure should have been worked out earlier, using the applicable FC and then translated into A$.

Other figures in the calculation statement are either of the following:

A$ amounts, such as pay as you go (PAYG) instalments raised
amounts translated into A$ previously, such as any foreign income tax offset.

Currency codes for label 80

These currency codes are from international standard ISO 4217 – Currency codes.

refer:ATO

Please contact Wiselink Accountants if you require further information

Easy guide to functional currency rules