Private ruling: International issues - permanent establishments
Date of advice: 11 July 2022
Published: October 2022

Ruling: Q1: Is certain income derived by Foreign Co 1 assessable income under subsection 6-5(3) of the Income Tax Assessment Act 1997 (ITAA 1997)? | A1: No. | Q2: Is certain income derived by Foreign Co 2 under the Agreement entered into between Foreign Co 1 and Foreign Co 2 assessable income under subsection 6-5(3) of the ITAA 1997? | A2: No. | Q3: Does Foreign Co 1 have a permanent establishment in Australia as defined in subsection 6(1) of the Income Tax Assessment Act 1936 (ITAA 1936) as a result of the activities performed in Australia by Aus Co or its employees? | A3: No. | Q4: Does Foreign Co 2 have a permanent establishment in Australia as defined in subsection 6(1) of the ITAA 1936 as a result of the activities performed in Australia by Aus Co or its employees? | A4: No.