Private ruling: Income tax treatment in respect of arrangement involving an Offshore Banking Unit
Date of advice: 25 September 2015
Published: September 2015

Ruling: In order to protect the privacy of this taxpayer and the commercial in-confidence components of this particular arrangement, the Edited Version is prepared in the following form. | The ruling concerns the income tax treatment in respect of an arrangement involving an Offshore Banking Unit and an overseas permanent establishment and the following provisions apply:


Relevant legislative provisions: Income Tax Assessment Act 1936, Division 9A | Income Tax Assessment Act 1936, Section 23AH | Income Tax Assessment Act 1936, Section 121C | Income Tax Assessment Act 1936, Section 121D | Income Tax Assessment Act 1936, Section 121E | Income Tax Assessment Act 1936, Section 121EA | Income Tax Assessment Act 1936, Section 121EB | Income Tax Assessment Act 1936, Section 121ED | Income Tax Assessment Act 1936, Section 121EE | Income Tax Assessment Act 1936, Subsection 121EG(3A) | Income Tax Assessment Act 1936, Subsection 128(1A) | Income Tax Assessment Act 1936, Subsection 128A(1AB) | Income Tax Assessment Act 1936, Section 128AE | Income Tax Assessment Act 1936, Section 128B | Income Tax Assessment Act 1936, Section 128GB | Income Tax Assessment Act 1936, Section 317 | Income Tax Assessment Act 1936, Section 320 | Income Tax Assessment Act 1936, Section 432 | Income Tax Assessment Act 1936, Section 433 | Income Tax Assessment Act 1936, Section 434 | Income Tax Assessment Act 1936, Section 435 | Income Tax Assessment Act 1936, Section 436 | Income Tax Assessment Act 1936, Section 446 | Income Tax Assessment Act 1997, Division 770 | Income Tax Assessment Act 1997, Section 770-10 | Income Tax Assessment Act 1997, Section 770-15 | Income Tax Assessment Act 1997, Section 815-225