Transfer pricing issues related to inbound distribution arrangements

margin earned by an inbound distributor can be affected by a range of commercial factors. However, we consider the EBIT margin provides ... year weighted average EBIT margin. 42. In calculating the 5-year weighted average EBIT margin, where possible, we use financial information which

Transfer pricing issues related to projects involving the use in Australian waters of non-resident owned mobile offshore drilling units - ATO compliance approach

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... equivalent operating margin (that is, EBIT [7] / sales [8] ). 44. After deriving the operating margin outcome for the Australian operations for the

ATO compliance approach to the arm's length debt test

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... paragraph 45 of this Guideline). Medium Arrangements that are not eligible for 'white', 'low' or 'low to moderate' risk zones, facts and

Allocation of professional firm profits - ATO compliance approach

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... you can submit an Early engagement advice request . 13. Overall, schemes which are designed to ensure that the IPP is not directly

Product Stewardship (Oil) Benefit: the meaning of the expression 'goods produced from used oil' and the terms 'filtered', 'de-watered', and 'de-mineralised' for the purposes of the Product stewardship for oil benefit scheme.

class of entities in relation to a particular scheme or a class of schemes. If you rely on this ruling, we must ... the context of the Product stewardship for oil benefit scheme (PSO scheme); [1] • the meaning of 'recycled oil'; • the meaning of 'oils

Application of section 45B of the Income Tax Assessment Act 1936 to demergers

form and substance of the scheme. A scheme which takes the form of a demerger scheme is one which accords with the ... the scheme from the point of view of the scheme's coincidence with events or circumstances beyond the scheme itself. In particular

Advance Pricing Arrangements

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... that the taxpayer is engaging in tax avoidance activities or schemes. • There are significant differences in views between the taxpayer and

Income tax: is an exceptional circumstances relief payment paid to a farmer under the Farm Household Support Act 1992 'assessable primary production income' under subsection 392-80(2) of the Income Tax Assessment Act 1997?

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... class of entities in relation to a particular scheme or a class of schemes. If you rely on this ruling, we must

Income tax: can Part IVA of the Income Tax Assessment Act 1936 apply to an asymmetric swap scheme?

parties choose to terminate the scheme, the action (itself a scheme) of terminating the original scheme would point to the existence ... the scheme 64. This factor is directed to examining the scheme for discrepancies between the form of the scheme and its substance

Income tax: in what circumstances does a contractual right, which is subject to the satisfaction of a condition, become a right to acquire a beneficial interest in a share for the purposes of subsection 83A-340(1) of the Income Tax Assessment Act 1997 ?

class of entities in relation to a particular scheme or a class of schemes. If you rely on this ruling, the Commissioner ... intends to implement its employee share scheme in conjunction with its Short Term Incentive Scheme (STIS). 9. At the beginning of each

Compendium

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... single amount of statutory income which is taxed at either marginal tax rates or a flat corporate tax rate. However, superannuation funds

Income tax: Division 35 - non-commercial business losses

income in the current year. In addition, the Exception allows eligible individuals to deduct amounts under section 40-880 (business related costs ... into account will not include a Goods and Services Tax ('GST') component: see section 17-5 of the ITAA 1997. Making

Fringe benefits tax: the operation of the new fringe benefits tax gross-up formula to apply from 1 April 2000

are GST-creditable benefits under section 149A (see paragraph 35 for the meaning of a GST-creditable benefit). 13. A GST-creditable ... same GST group, and either that person or that member of the same GST group is entitled to a GST input tax

Income tax: the taxation consequences for taxpayers issuing certain stapled securities

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... Identification of the scheme 26. Where a taxpayer issues a Stapled Security as described in this Ruling, the scheme may vary from

Income tax: deductions that relate to personal services income

New Tax System (Goods and Services Tax) Act 1999 (GST Act). 10. Note also that the general anti-avoidance provisions of Part ... that has unanimously resolved that it be treated as an 'eligible local governing body' and the resolution has not been cancelled. Such

Income tax: government payments to industry to assist entities (including individuals) to continue, commence or cease business

with reference to the value of sales (excluding WET and GST liability). The rebate is received in the ordinary course of the ... restrict an industry. The government is offering assistance to eligible businesses through a restructure package. The taxpayer incurs costs in seeking financial

Income tax: meaning of 'Australian superannuation fund' in subsection 295-95(2) of the Income Tax Assessment Act 1997

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... class of entities in relation to a particular scheme or a class of schemes. If you rely on this ruling, we must

Income tax: business related capital expenditure - section 40-880 of the Income Tax Assessment Act 1997 core issues

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... class of entities in relation to a particular scheme or a class of schemes. If you rely on this ruling, we must

Income tax: the operation of subsection 230-55(4) of the Income Tax Assessment Act 1997 (ITAA 1997) in determining what is an 'arrangement' for the purposes of the taxation of financial arrangements under Division 230 of the ITAA 1997.

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... class of entities in relation to a particular scheme or a class of schemes. If you rely on this ruling, we must

Compendium

who import goods or services to register, report and pay GST in Australia. Securely access through AusID. Log in with AusID Access ... income Prior to age 60 for taxed schemes, and at all ages for untaxed schemes, any lump sum commutation payment is clearly