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Edited version of your private ruling
Authorisation Number: 1012486102101
Ruling
Subject: Permanent establishment
The issue concerned the following:
Will the income derived by Company A, an entity which is resident in Country X, in respect of the activities forming part of the arrangement set out in the present private ruling application be assessable income of Company A for the purposes of subsection 6-5(3) of the Income Tax Assessment Act 1997 (ITAA 1997)?
The Commissioner has ruled:
No. The income derived by Company A, an entity which is resident in Country X, in respect of the activities forming part of the Arrangement, will not be assessable income of Company A for the purposes of subsection 6-5(3) of the ITAA 1997.