Petroleum Resource Rent Tax Assessment Act 1987
This section applies to deciding, under section 51 , whether any of the following ( tax effects ) would have occurred, or might reasonably be expected to have occurred, if an arrangement had not been entered into or carried out: (a) an amount of assessable receipts being derived by the person in relation to a petroleum project; (b) an amount of deductible expenditure not being incurred by the person in relation to a petroleum project.
51A(2)
A decision that a tax effect would have occurred if the arrangement had not been entered into or carried out must be based on a postulate that comprises only the events or circumstances that actually happened or existed (other than those that form part of the arrangement).
51A(3)
A decision that a tax effect might reasonably be expected to have occurred if the arrangement had not been entered into or carried out must be based on a postulate that is a reasonable alternative to entering into or carrying out the arrangement.
51A(4)
In determining for the purposes of subsection (3) whether a postulate is such a reasonable alternative: (a) have particular regard to:
(i) the substance of the arrangement; and
(b) disregard any result in relation to the operation of this Act that would be achieved by the postulate for any person (whether or not a party to the arrangement).
(ii) any result or consequence for the person that is or would be achieved by the arrangement (other than a result in relation to the operation of this Act); but
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