Income Tax Assessment Act 1997
An entity gets a transfer pricing benefit from the attribution of profits to a *PE of the entity if:
(a) the amount of profits (the actual profits ) attributed to the PE differs from the *arm ' s length profits for the PE; and
(b) had the arm ' s length profits, instead of the actual profits, been attributed to the PE, one or more of the following would, apart from this Subdivision, apply:
(i) the amount of the entity ' s taxable income for an income year would be greater ;
(ii) the amount of the entity ' s loss of a particular *sort for an income year would be less ;
Nil amounts 815-220(2)
(iii) the amount of the entity ' s *tax offsets for an income year would be less .
For the purposes of this section:
(a) treat an entity that has no taxable income for an income year as having a taxable income for the year of a nil amount; and
(b) treat an entity that has no loss of a particular *sort for an income year as having a loss of that sort for the year of a nil amount; and
(c) treat an entity that has no *tax offsets for an income year as having tax offsets for the year of a nil amount.
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