Income Tax Assessment Act 1997
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Hide history noteSECTION 815-5 815-5 Object
The object of this Subdivision is to ensure the following amounts are appropriately brought to tax in Australia, consistent with the arm ' s length principle:
(a) profits which would have accrued to an Australian entity if it had been dealing at * arm ' s length , but, by reason of non-arm ' s length conditions operating between the entity and its foreign associated entities, have not so accrued;
(b) profits which an Australian permanent establishment (within the meaning of the relevant * international tax agreement ) of a foreign entity might have been expected to make if it were a distinct and separate entity engaged in the same or similar activities under the same or similar conditions, but dealing wholly independently.
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