s 815-5
In forceCross‑border transfer pricing guidance
Chapter 4International aspects of income tax
Part 4-5General
Division 815Cross‑border transfer pricing
Subdivision 815-ACross‑border transfer pricing
815-5 Cross‑border transfer pricing guidance
Despite section 815‑20 of the Income Tax Assessment Act 1997, the documents covered by that section for an income year that starts before 1 July 2012 are taken to be as follows:
(a)
the Model Tax Convention on Income and on Capital, and its Commentaries, as adopted by the Council of the Organisation for Economic Cooperation and Development and last amended before the start of the income year;
(b)
the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, as approved by that Council and last amended before the start of the income year.
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