Tax Laws Amendment (Countering Tax Avoidance and Multinational Profit Shifting) Act 2013 (101 of 2013)
Schedule 2 Modernisation of transfer pricing rules
Part 1 Main amendments
Taxation Administration Act 1953
4 At the end of section 284-150 in Schedule 1
Add:
Scheme shortfall amount for cross-border transfer pricing
(4) Despite subsection (2), your scheme shortfall amount for a *scheme to which subsection 284-145(2B) applies is the total amount of additional income tax and *withholding tax you are liable to pay as mentioned in that subsection.
(5) Disregard your *scheme shortfall amount for a *scheme to which subsection 284-145(1) applies to the extent that scheme shortfall amount is attributable to additional tax that is, or is part of, your scheme shortfall amount for a scheme to which subsection 284-145(2B) applies.