Commonwealth Consolidated Acts Commonwealth Consolidated ActsThe object of this Subdivision is to ensure the following amounts are appropriately brought to tax in Australia, consistent with the arm's length principle:
(a) profits which would have accrued to an Australian entity if it had been dealing at * arm's length, but, by reason of non - arm's length conditions operating between the entity and its foreign associated entities, have not so accrued;
(b) profits which an Australian permanent establishment (within the meaning of the relevant * international tax agreement) of a foreign entity might have been expected to make if it were a distinct and separate entity engaged in the same or similar activities under the same or similar conditions, but dealing wholly independently.