Commonwealth Consolidated Acts Commonwealth Consolidated Acts(1) For the purposes covered by subsection (2), if an entity gets a * transfer pricing benefit from the attribution of profits to a * PE of the entity:
(a) the amount of profits actually attributed to the PE is taken not to have been so attributed; and
(b) instead, the * arm's length profits are taken to have been attributed to the PE.
Note: There are special rules about documentation that affect when an entity has a reasonably arguable position about the application (or non - application) of this Subdivision: see Subdivision 284 - E in Schedule 1 to the Taxation Administration Act 1953 .
(2) The purposes covered by this subsection are:
(a) if the * transfer pricing benefit arises under subparagraph 815 - 220(1)(b)(i)--working out the amount (if any) of the entity's taxable income for the income year; and
(b) if the transfer pricing benefit arises under subparagraph 815 - 220(1)(b)(ii)--working out the amount (if any) of a loss of a particular * sort for the income year; and
(c) if the transfer pricing benefit arises under subparagraph 815 - 220(1)(b)(iii)--working out the amount (if any) of the entity's * tax offsets for the income year.