Explanatory Memorandum
(Circulated by the authority of the Deputy Prime Minister and Treasurer, the Hon Wayne Swan MP)Glossary
The following abbreviations and acronyms are used throughout this explanatory memorandum.
| Abbreviation | Definition |
| ATO | Australian Taxation Office |
| Commissioner | Commissioner of Taxation |
| ITAA 1936 | Income Tax Assessment Act 1936 |
| ITAA 1953 | International Tax Agreement Act 1953 |
| ITAA 1997 | Income Tax Assessment Act 1997 |
| IT(TP) Act 1997 | Income Tax (Transitional Provisions) Act 1997 |
| MAP | mutual agreement procedure article |
| OECD | Organisation for Economic Co-operation and Development |
| OECD Guidelines | OECD's Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations |
| OECD Model | OECD Model Tax Convention on Income and on Capital |
| SNF | Commissioner of Taxation v SNF (Australia) Pty Ltd [2011] FCAFC 74 |
| TAA 1953 | Taxation Administration Act 1953 |