Income Tax Assessment Act 1936
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.
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