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Legislation
ATO documents that consider ITAA 1936 s 23AH
39 documents
Interim arrangements in response to the Multinational Anti Avoidance Law (MAAL)
Arrangements involving offshore permanent establishments
Non-assessable non-exempt income: periodic payments received under a swap arrangement
Capital Gains Tax: disposal of goodwill by a branch to another entity
Foreign income - non-assessable and non-exempt: substantial equipment permanent establishment in a listed country
Section 23AH of the Income Tax Assessment Act 1936 and drilling rig deployed outside the exclusive economic zone (EEZ) of a foreign country
Permanent Establishment of a US Limited Liability Company
OECD hybrid mismatch rules - concept of structured arrangement
Intangibles arrangements
Income tax: is an amount that is a cost in relation to a debt interest covered by paragraph 820-40(1)(a) of the Income Tax Assessment Act 1997 (ITAA 1997) deductible under section 25-90 of the ITAA 1997 (or, alternatively, under subsection 230-15(3) of the ITAA 1997) where that amount is incurred in earning income that meets the requirements of both section 23AH of the Income Tax Assessment Act 1936 and section 768-5 of the ITAA 1997?
Income tax: Permanent establishment - What is 'a place at or through which [a] person carries on any business' in the definition of permanent establishment in subsection 6(1) of the Income Tax Assessment Act 1936?
Income tax: branch funding for multinational banks
Income tax: entitlement to foreign income tax offsets under section 770-10 of the Income Tax Assessment Act 1997 where income is derived from investing in fiscally transparent foreign entities
Capital gains and losses: exemptions - expiry of a lease - non-assessable non-exempt income
Non-portfolio dividend received by a taxpayer through its permanent establishment in Hong Kong
Permanent establishment of a US Limited Liability Company
Assessability of foreign branch income derived from New Zealand
Assessability of foreign branch income derived from New Zealand
Application of subsection 23AH(2): deemed permanent establishment (PE) and carrying on of business - Article 5.4 of the 1995 New Zealand Agreement