Income Tax Assessment Act 1997



Division 815 - Cross-border transfer pricing  

Subdivision 815-C - Arm ' s length principle for permanent establishments  

Operative provisions

SECTION 815-210   Operation of Subdivision  

Nothing in the provisions of this Act other than this Subdivision limits the operation of this Subdivision.

Nothing in this Subdivision limits Division 820 (about thin capitalisation) in its application to reduce, or further reduce, *debt deductions of an entity.

For the purposes of this Subdivision, a branch to which subsection 160ZZW(2) of the Income Tax Assessment Act 1936 (about certain Australian branches of foreign banks) applies is taken not to be, and not to have been at any time since its establishment, a *permanent establishment in Australia of the bank.


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