Document ID: chunk:federal_register_of_legislation:C2012A00126:clause:1_2
Version: federal_register_of_legislation:C2012A00126
Segment Type: clause
Provision Reference: sch 1 cl 2
Character Range: 36135–36773

2  Subparagraphs 842‑250(1)(c)(i) and (ii)
Repeal the subparagraphs, substitute:
 (i) in respect of an entity that is resident in a country that has entered into an *international tax agreement with Australia containing a *business profits article—amounts included in the assessable income of the fund are treated as having a source in Australia because they are attributable to a permanent establishment of the fund in Australia; or
 (ii) in respect of an entity that has not entered into an international tax agreement with Australia—the Commissioner makes a determination under section 136AE of the Income Tax Assessment Act 1936; or