Taxation Ruling

TR 94/14R - Erratum

Income tax: application of Division 13 of Part III (international profit shifting) - some basic concepts underlying the operation of Division 13 and some circumstances in which section 136AD will be applied.


This Erratum is a public ruling for the purposes of the Taxation Administration Act 1953. It corrects an error in the table at paragraph 272 of Taxation Ruling TR 94/14.

The table at paragraph 272 was constructed to list all the basic combinations covered by the concept of an 'international agreement', as defined in section 136AC of the Income Tax Assessment Act 1936.

The reference in the table in the third column heading in the first row at paragraph 272 of TR 94/14 to 'offshore' is an error and the correct reference should be to 'onshore'.

TR 94/14 is corrected as follows:

1. Paragraph 272

Omit the third column heading in the first row of the table; substitute:

NR company operating onshore but not through a PE

This Erratum applies on and from 31 May 1994.

Commissioner of Taxation
14 December 2011


ATO references:

ISSN 1039 - 0731