ITAA 1936 s 13 of Part III

Income tax: application of Division 13 of Part III and double tax agreements to permanent establishments

Income tax: thin capitalisation - applying the arm's length debt test

Income tax: application of the Australia/New Zealand Double Tax Agreement to New Zealand Resident Trustees of New Zealand Foreign Trusts

Income tax: the interaction of Division 820 of the Income Tax Assessment Act 1997 and the transfer pricing provisions in relation to costs that may become debt deductions, for example, interest and guarantee fees

Income tax: research and development tax offsets - the at risk rule

Income tax: international transfer pricing - practical issues associated with setting, reviewing and documenting transfer pricing - application of Division 13 of Part III (international profit shifting) and Australia's comprehensive double taxation agreements

International Transfer Pricing - Making a determination under Division 13 of Part III of the Income Tax Assessment Act 1936 and applying the Business Profits Article or Associated Enterprises Article of Australia's Double Tax Agreements.

The Transfer Pricing Review Panel (TPRP)

Referral of work to International Strategy and Operations

ATO's Advance Pricing Arrangement Program

Income tax: where there is no excess debt under Division 820 of the Income Tax Assessment Act 1997 can the transfer pricing provisions apply to adjust the pricing of costs that may become debt deductions, for example, interest and guarantee fees?

Notice of Withdrawal - Income tax: where there is no excess debt under Division 820 of the Income Tax Assessment Act 1997, can the transfer pricing provisions apply to adjust the pricing of costs that may become debt deductions, for example, interest and guarantee fees?

Income tax: where a taxpayer has supplied or acquired property under an international agreement and that gives rise to a debt interest or an equity interest as defined for the purposes of Division 974 of the Income Tax Assessment Act 1997 , does Division 974 bear upon the characterisation to be adopted for the purposes of the application of Division 13 of Part III of the Income Tax Assessment Act 1936 to the transaction?

Income tax: international transfer pricing: the effects of determinations made under Division 13 of Part III, including consequential adjustments under section 136AF