TAXATION ADMINISTRATION ACT 1953
SCHEDULE 1
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COLLECTION AND RECOVERY OF INCOME TAX AND OTHER LIABILITIES
PART 4-25
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CHARGES AND PENALTIES
Division 284
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Administrative penalties for statements, unarguable positions and schemes
Subdivision 284-E
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Special rules about unarguable positions for cross-border transfer pricing
SECTION 284-250
284-250
UNDOCUMENTED TRANSFER PRICING TREATMENT NOT REASONABLY ARGUABLE
This Division has effect in relation to an entity as if a matter was not * reasonably arguable if:
(a) the matter is a particular way of applying (including not applying) Subdivision 815-B or 815-C of the Income Tax Assessment Act 1997 to a matter (or identical matters); and
(b) the entity does not have records that meet the requirements in this Subdivision for the application of the Subdivision mentioned in paragraph (a) to that matter (or those matters) in that way.
View history note
Hide history noteNote: See section 3AA .
Chapter 4 - Generic assessment, collection and recovery rulesThis Division has effect in relation to an entity as if a matter was not * reasonably arguable if:
(a) the matter is a particular way of applying (including not applying) Subdivision 815-B or 815-C of the Income Tax Assessment Act 1997 to a matter (or identical matters); and
(b) the entity does not have records that meet the requirements in this Subdivision for the application of the Subdivision mentioned in paragraph (a) to that matter (or those matters) in that way.
Note:
For the Commissioner ' s power to remit an administrative penalty imposed by this Part, see section 298-20 .
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