Income Tax Assessment Act 1997
CHAPTER 4
-
INTERNATIONAL ASPECTS OF INCOME TAX
PART 4-5
-
GENERAL
Division 815
-
Cross-border transfer pricing
Subdivision 815-C
-
Arm
'
s length principle for permanent establishments
Operative provisions
SECTION 815-210
Operation of Subdivision
815-210(1)
Nothing in the provisions of this Act other than this Subdivision limits the operation of this Subdivision. 815-210(2)
Nothing in this Subdivision limits Division 820 (about thin capitalisation) in its application to reduce, or further reduce, *debt deductions of an entity. 815-210(3)
For the purposes of this Subdivision, a branch to which subsection 160ZZW(2) of the Income Tax Assessment Act 1936 (about certain Australian branches of foreign banks) applies is taken not to be, and not to have been at any time since its establishment, a *permanent establishment in Australia of the bank.
View history note
Hide history note[ CCH Note: For the application of Subdivisions 815-B , 815-C and 815-D of the Income Tax Assessment Act 1997 , as inserted, see Division 815 of the Income Tax (Transitional Provisions) Act 1997 .]
Nothing in the provisions of this Act other than this Subdivision limits the operation of this Subdivision. 815-210(2)
Nothing in this Subdivision limits Division 820 (about thin capitalisation) in its application to reduce, or further reduce, *debt deductions of an entity. 815-210(3)
For the purposes of this Subdivision, a branch to which subsection 160ZZW(2) of the Income Tax Assessment Act 1936 (about certain Australian branches of foreign banks) applies is taken not to be, and not to have been at any time since its establishment, a *permanent establishment in Australia of the bank.
[ CCH Note: For the application of Subdivisions 815-B , 815-C and 815-D of the Income Tax Assessment Act 1997 , as inserted, see Division 815 of the Income Tax (Transitional Provisions) Act 1997 .]
This information is provided by CCH Australia Limited Link opens in new window. View the disclaimer and notice of copyright.