WebbAdministration Act 1953 (TAA 1953). If an entity does not meet these requirements, Division 284 of Schedule 1 to the TAA 1953 (dealing with administrative penalties) will … Webbrecommended to evidence compliance with the arm’s length principle and to demonstrate a reasonably arguable position in the event of a transfer pricing adjustment and, in so doing, access to reduced. Most appropriate method approach ... Administration Act 1953 (TAA 1953), (hereinafter collectively referred to as the ‘new transfer pricing ...
TR 92/1 Legal database
A matter is reasonably arguable if it satisfies the requirements of section 284-15 of Schedule 1 to the Taxation Administration Act 1953(as amended) (TAA). This is different to the definition of a Category A RTP. A position that is reasonably arguable may still need to be disclosed on the RTP schedule as a … Visa mer You must also disclose a material position that is not supported by relevant authorities if is not based on a well-reasoned construction of the applicable statutory … Visa mer To work out whether a material position is a Category A RTP, you must have regard to relevant authorities. For the purposes of the RTP schedule, the phrase … Visa mer The reasonably arguable standard is an objective standard. All authorities relevant to the tax treatment of circumstances, arrangements or transactions, including the … Visa mer In concluding whether a position involving an assumption about the way in which the Commissioner of Taxation will exercise a discretion, including the … Visa mer Webb(2) In deciding whether it is *reasonably arguable that a *scheme benefit would be available at law, take into account any thing that the Commissioner can do under a … ear wax from ear candling
Explanatory Memorandum - Modernisation of transfer pricing …
WebbTAA 1953 to ensure administrative penalties apply where a significant global entity does not lodge a general purpose financial statement as required under the taxation law to … http://classic.austlii.edu.au/au/legis/cth/consol_act/taa1953269/ Webb1 apr. 2024 · The concept of a reasonably arguable position was used in former sections 226K (penalty tax where unarguable position taken) and 222C (which defined the … ear wax halloween treat