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Edited version of your written advice
Authorisation Number: 1012878997169
Date of advice: 25 September 2015
Ruling
Subject: Income tax treatment in respect of arrangement involving an Offshore Banking Unit
In order to protect the privacy of this taxpayer and the commercial in-confidence components of this particular arrangement, the Edited Version is prepared in the following form.
The ruling concerns the income tax treatment in respect of an arrangement involving an Offshore Banking Unit and an overseas permanent establishment and the following provisions apply:
Relevant legislative provisions
Income Tax Assessment Act 1936, Division 9A
Income Tax Assessment Act 1936, Section 23AH
Income Tax Assessment Act 1936, Section 121C
Income Tax Assessment Act 1936, Section 121D
Income Tax Assessment Act 1936, Section 121E
Income Tax Assessment Act 1936, Section 121EA
Income Tax Assessment Act 1936, Section 121EB
Income Tax Assessment Act 1936, Section 121ED
Income Tax Assessment Act 1936, Section 121EE
Income Tax Assessment Act 1936, Subsection 121EG(3A)
Income Tax Assessment Act 1936, Subsection 128(1A)
Income Tax Assessment Act 1936, Subsection 128A(1AB)
Income Tax Assessment Act 1936, Section 128AE
Income Tax Assessment Act 1936, Section 128B
Income Tax Assessment Act 1936, Section 128GB
Income Tax Assessment Act 1936, Section 317
Income Tax Assessment Act 1936, Section 320
Income Tax Assessment Act 1936, Section 432
Income Tax Assessment Act 1936, Section 433
Income Tax Assessment Act 1936, Section 434
Income Tax Assessment Act 1936, Section 435
Income Tax Assessment Act 1936, Section 436
Income Tax Assessment Act 1936, Section 446
Income Tax Assessment Act 1997, Division 770
Income Tax Assessment Act 1997, Section 770-10
Income Tax Assessment Act 1997, Section 770-15
Income Tax Assessment Act 1997, Section 815-225