Income Tax Assessment Act 1936
(a) the amount the interposed entity paid or lent the target entity; and
(b) how much (if any) of that amount the Commissioner believes represented consideration payable to the target entity by:
(i) the trustee; or
for anything (assuming that the consideration payable equals that for similar transactions at arm's length). 109XH(3) [ Unpaid present entitlement amount]
(ii) any of the interposed entities;
The total of the amounts determined under subsection (1) for payments and loans in relation to which section 109XB applies because of the same present entitlement mentioned in paragraph 109XA(1)(c) , (2)(b) or (3)(b) must not exceed the unpaid present entitlement mentioned in subsection 109XA(4) .Timing of payment or loan 109XH(4)
The trustee is taken under section 109XF or 109XG to have made the payment or loan at the time the interposed entity made the payment or loan mentioned in paragraph 109XF(1)(c) or 109XG(1)(c) to the target entity.