Private ruling: Arrangement involving an Offshore Banking Unit and an overseas permanent establishment.
Date of advice: 8 December 2021
Published: March 2022

Ruling: The Commissioner made a private ruling on the income tax treatment in respect of an arrangement involving an Offshore Banking Unit and an overseas permanent establishment.


Relevant legislative provisions: Income Tax Assessment Act 1936 Division 9A | Income Tax Assessment Act 1936 section 23AH | Income Tax Assessment Act 1936 section 121A | Income Tax Assessment Act 1936 section 121C | Income Tax Assessment Act 1936 section 121D | Income Tax Assessment Act 1936 subsection 121D(2) | Income Tax Assessment Act 1936 subsection 121D(4) | Income Tax Assessment Act 1936 subsection 121D(4A) | Income Tax Assessment Act 1936 subsection 121D(6) | Income Tax Assessment Act 1936 subsection 121D(6A) | Income Tax Assessment Act 1936 section 121E | Income Tax Assessment Act 1936 section 121EA | Income Tax Assessment Act 1936 section 121EAA | Income Tax Assessment Act 1936 section 121EB | Income Tax Assessment Act 1936 section 121ED | Income Tax Assessment Act 1936 section 121EDA | Income Tax Assessment Act 1936 section 121EE | Income Tax Assessment Act 1936 section 121EF | Income Tax Assessment Act 1936 subsection 121EG(3A) | Income Tax Assessment Act 1936 subsection 262A(1A) | Income Tax Assessment Act 1936 subsection 262A(1AA) | Income Tax Assessment Act 1936 subsection 128AE(2) | 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 230 | Income Tax Assessment Act 1997 section 6-1 | Income Tax Assessment Act 1997 section 8-1 | Income Tax Assessment Act 1997 Division 770 | Income Tax Assessment Act 1997 section 770-10 | Income Tax Assessment Act 1997 section 770-15