| Disclaimer You cannot rely on this record in your tax affairs. It is not binding and provides you with no protection (including from any underpaid tax, penalty or interest). In addition, this record is not an authority for the purposes of establishing a reasonably arguable position for you to apply to your own circumstances. For more information on the status of edited versions of private advice and reasons we publish them, see PS LA 2008/4. |
Edited version of private advice
Authorisation Number: 1051929864532
Date of advice: 8 December 2021
Ruling
Subject: Arrangement involving an Offshore Banking Unit and an overseas permanent establishment.
The Commissioner made a private ruling on the income tax treatment in respect of an arrangement involving an Offshore Banking Unit and an overseas permanent establishment.
Relevant legislative provisions
Income Tax Assessment Act 1936 Division 9A
Income Tax Assessment Act 1936 section 23AH
Income Tax Assessment Act 1936 section 121A
Income Tax Assessment Act 1936 section 121C
Income Tax Assessment Act 1936 section 121D
Income Tax Assessment Act 1936 subsection 121D(2)
Income Tax Assessment Act 1936 subsection 121D(4)
Income Tax Assessment Act 1936 subsection 121D(4A)
Income Tax Assessment Act 1936 subsection 121D(6)
Income Tax Assessment Act 1936 subsection 121D(6A)
Income Tax Assessment Act 1936 section 121E
Income Tax Assessment Act 1936 section 121EA
Income Tax Assessment Act 1936 section 121EAA
Income Tax Assessment Act 1936 section 121EB
Income Tax Assessment Act 1936 section 121ED
Income Tax Assessment Act 1936 section 121EDA
Income Tax Assessment Act 1936 section 121EE
Income Tax Assessment Act 1936 section 121EF
Income Tax Assessment Act 1936 subsection 121EG(3A)
Income Tax Assessment Act 1936 subsection 262A(1A)
Income Tax Assessment Act 1936 subsection 262A(1AA)
Income Tax Assessment Act 1936 subsection 128AE(2)
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 230
Income Tax Assessment Act 1997 section 6-1
Income Tax Assessment Act 1997 section 8-1
Income Tax Assessment Act 1997 Division 770
Income Tax Assessment Act 1997 section 770-10
Income Tax Assessment Act 1997 section 770-15