Document ID: chunk:federal_register_of_legislation:C2025C00029:section:4:p8
Version: federal_register_of_legislation:C2025C00029
Segment Type: section
Provision Reference: s 4 (pt 8/25)
Character Range: 7331742–7334697

both the holder and the issuer of the interest (the issuer), and in relation to only that part of the overlapped period that falls within the relevant period, either or both of the following apply:
 (i) the *valuation days used to calculate the average value of the holder's assets are different from the valuation days used to calculate the issuer's *adjusted average debt;
 (ii) the number of valuation days used to calculate the average value of the holder's assets are different from the number of valuation days used to calculate the issuer's adjusted average debt.
 (4) This subsection covers a *debt interest held by an entity (the holder) at the particular time mentioned in subsection (2) if:
 (a) subsection (1) does not apply to the holder for a period that is, or includes, all or a part of the relevant period; and
 (b) at that time, the debt interest has been *on issue for a period of less than 180 days.
However, if the total period for which the interest remains on issue is 180 days or more, this subsection is taken not to have covered the interest at that time.
 (5) For the purposes of subsection (2), take into account the value of a *debt interest issued by a *foreign entity only to the extent that the interest is attributable to assets covered by subparagraph (1)(b)(i) or (ii) that are held by the foreign entity throughout the relevant period.

Subdivision 820‑L—Record keeping requirements

Guide to Subdivision 820‑L

820‑950  What this Subdivision is about
      This Subdivision sets out special record keeping requirements and related provisions about the following:

                (a) an entity that carries on its business at or through its Australian permanent establishments;
                (b) an arm's length debt amount or arm's length capital amount worked out under this Division.

Table of sections

Records about Australian permanent establishments
820‑960 Records about Australian permanent establishments
820‑962 Records about Australian permanent establishments—exemptions from Australian accounting standards
820‑965 Review of Commissioner's decision

Records about arm's length amounts
820‑980 Records about arm's length capital amount
820‑985 Records about group ratio

Offences committed by certain entities
820‑990 Offences—treatment of partnerships
820‑995 Offences—treatment of unincorporated companies

Records about Australian permanent establishments

820‑960  Records about Australian permanent establishments
 (1) If an entity:
 (a) is an *inward investor (financial) or *inward investing entity (ADI), for all or a part of an income year; and
 (b) carries on its *business at or through one or more of its *Australian permanent establishments throughout that year; and
 (c) has total revenues attributable to those Australian permanent establishments for that year that are at least $2,000,000;
the entity must keep for that year the records for which subsection (1A) or (1B) provides.
Note: