Income Tax Assessment Act 1936
Pt IVA inserted by No 110 of 1981.
The primary objects of the DPT provisions are:
(a) to ensure that the Australian tax payable by significant global entities properly reflects the economic substance of the activities that those entities carry on in Australia; and
(b) to prevent those entities from reducing the amount of Australian tax they pay by diverting profits offshore through contrived arrangements between related parties. 177H(2)
In addition, the DPT provisions (in combination with Division 145 in Schedule 1 to the Taxation Administration Act 1953 ) have the object of encouraging significant global entities to provide sufficient information to the Commissioner to allow for the timely resolution of disputes about Australian tax.
S 177H inserted by No 27 of 2017, s 3 and Sch 1 item 13, applicable in relation to DPT tax benefits for a year of income that starts on or after 1 July 2017 (whether or not the DPT tax benefit arises in connection with a scheme that was entered into, or was commenced to be carried out, before 1 July 2017).
Former s 177H repealed by
No 143 of 2007
, s 3 and Sch 1 item 76, applicable in relation to income years, statutory accounting periods and notional accounting periods starting on or after the first 1 July that occurs after 24 September 2007. For savings provisions, see note under s
. S 177H formerly read:
SECTION 177H AMENDMENT OF FOREIGN TAX CREDIT DETERMINATIONS
Section 160AK does not prevent the amendment of a foreign tax credit determination at any time before the end of 6 years after the original determination date if the amendment is for the purposes of giving effect to subsection 177F(1) .
Section 160AK does not prevent the amendment of a foreign tax credit determination at any time if the amendment is for the purpose of giving effect to subsection 177F(3) .
For the purposes of this section, a foreign tax credit determination is a determination under Division 19 of Part III .
For the purposes of this section, the original determination date for a foreign tax credit determination has the same meaning as in section 160AK .
Former s 177H inserted by No 11 of 1999.
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