ITAA 1936 definition

ITAA 1936 means the Income Tax Assessment Act 1936 (C’wth of Aust.).

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ITAA 1936 means the Income Tax Assessment Act 1936. “ITAA 1997” means the Income Tax Assessment Act

ITAA 1936 means Income Tax Assessment Act 1936 (Cth).

Examples of ITAA 1936 in a sentence

• Where a tax treaty exists, the Commissioner would usually raise a transfer pricing or profit reallocation adjustment under both Division 13 of the Income Tax Assessment Act 1936 (ITAA 1936) and the Associated Enterprises article (usually Article 9) of the relevant treaty.

• For the purposes of the underlying foreign tax credit rules, s 160AFB of the ITAA 1936 provides that companies are related if there is control of 10% or more of voting power.

• Domestic law Under Australian domestic law, jurisdiction to tax depends on residence and source and the PE concept is only relevant at other stages of the taxing process (such as making adjustments under subsection 136AE(4) of the Income Tax Assessment ▇▇▇ ▇▇▇▇ (ITAA 1936) or exemption of foreign branch profits under section 23AH of the ITAA 1936).

• The ITAA 1936 and ITAA 1997 contain a number of provisions under which entities are treated as related, but the definitions are inconsistent and none are particularly relevant to Art 11.151 Article 11(8), which deals with payments of interest in excess of an arm’s length amount, applies where there is a “special relationship” between the parties.

• The commercial debt forgiveness rules contained in Division 245 of the ITAA 1997 (or its predecessor provisions in Schedule 2C of the ITAA 1936), the value shifting rules contained in Divisions 723, 725 and 727 of the ITAA 1997 and the limited recourse debt rules contained in Division 243 of the ITAA 1997 have not applied in relation to any transaction, act or omission of any of the Evolution Group occurring or arising on or before Completion.

• No Target Entity has sought capital gains tax relief under sub-division 126B of the ITAA 1997 or section 160ZZO of the ITAA 1936 in respect of any asset acquired by any Target Entity and that is still owned by any Target Entity immediately after Completion.

• The commercial debt forgiveness rules contained in Division 245 of the ITAA 1997 (or its predecessor provisions in Schedule 2C of the ITAA 1936), the value shifting rules contained in Divisions 723, 725 and 727 of the ITAA 1997 and the limited recourse debt rules contained in Division 243 of the ITAA 1997 have not applied in relation to any transaction, act or omission of any of the Target Entities occurring or arising on or before the ▇▇ ▇▇▇▇▇▇ Accounts Date.

• None of these definitions are concerned with matters relevant to Art 11, US Treaty, nor are any other uses of the “related” concept in the legislation: See for example s 46B, ITAA 1936 and s 26-35, ITAA 1997.

• Target Entity has been, or has been agreed to be, released, waived, forgiven or otherwise extinguished in circumstances which attracted the operation of Division 245 of the ITAA 1997 or former Division 245 of Schedule 2C of the ITAA 1936.

• Avoidance No Target Entity has entered into or been a party to any transaction which contravenes, or may contravene, any anti-avoidance provisions of any Tax Law, including Part IVA of the ITAA 1936, for which there have been or could be an amended assessment for the Target Entity.

More Definitions of ITAA 1936

ITAA 1936 means the Income Tax Assessment Act 1936 (as amended). ‘ITAA 1997’ means the Income Tax Assessment Act 1997 (as amended). ‘party’ or ‘parties’ means the Taxpayers and/or the Commissioner. ‘person’ means any natural person and includes a firm, corporation, body corporate, unincorporated association or any governmental authority. ‘relevant years’ means the financial years ended 30 June 1997 to 30 June 2005. ‘SIC’ means Shortfall Interest Charge calculated pursuant to Division 280 of Schedule 1 of the TAA 1953. ‘TAA 1953’ means the Taxation Administration Act 1953 (as amended). ‘Taxpayers’ means Magellan Petroleum Australia Limited A.C.N. 009 728 581, Magellan Petroleum (N.T.) Pty Ltd A.C.N. 0▇▇ ▇▇▇ ▇▇▇ and Paroo Petroleum Pty Ltd A.C.N. 010 839 488. ‘the first taxpayer’ means Magellan Petroleum Australia Limited A.C.N. 009 728 581. ‘the second taxpayer’ means Magellan Petroleum (N.T.) Pty Ltd A.C.N. 0▇▇ ▇▇▇ ▇▇▇. ‘the third taxpayer’ means Paroo Petroleum Pty Ltd A.C.N. 010 839 488. ‘this Deed’ means this Deed of Settlement between the Commissioner and the Taxpayers.

ITAA 1936 means the Income Tax Assessment Act 1936 (as amended) and includes regulations made pursuant to the said Act

ITAA 1936 means the Income Tax Assessment Act 1936; “s606” (for example) means a section of the Act;

ITAA 1936 means the Income Tax Assessment Act 1936 (Cth).

ITAA 1936 the Income Tax Assessment Act 1936 (Australia);