ITAA 1936 s 362

ATO compliance approach to transfer pricing issues related to centralised operating models involving procurement, marketing, sales and distribution functions

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

Foreign hybrid rules: treatment of foreign hybrid company as a partnership

Classification of a German Kommanditgesellschaft for Australian income tax purposes

Controlled Foreign Companies: attribution of foreign income to Australian entity with de facto control of foreign entity - no direct or indirect attribution interest in that entity

ATO compliance approach to transfer pricing issues related to centralised operating models involving procurement, marketing, sales and distribution functions

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

ATO compliance approach to transfer pricing issues related to centralised operating models