Income Tax Assessment Act 1997

CHAPTER 4 - INTERNATIONAL ASPECTS OF INCOME TAX  

PART 4-5 - GENERAL  

Division 815 - Cross-border transfer pricing  

Subdivision 815-A - Treaty-equivalent cross-border transfer pricing rules  

Operative provisions

SECTION 815-10   Transfer pricing benefit may be negated  

815-10(1)  
The Commissioner may make a determination mentioned in subsection 815-30(1) , in writing, for the purpose of negating a * transfer pricing benefit an entity gets. Treaty requirement

815-10(2)  
However, this section only applies to an entity if:


(a) the entity gets the * transfer pricing benefit under subsection 815-15(1) at a time when an * international tax agreement containing an * associated enterprises article applies to the entity; or


(b) the entity gets the transfer pricing benefit under subsection 815-15(2) at a time when an international tax agreement containing a * business profits article applies to the entity.

Note:

This Subdivision does not apply to income years to which Subdivisions 815-B and 815-C apply: see section 815-1 of the Income Tax (Transitional Provisions) Act 1997 .


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