Document ID: chunk:federal_register_of_legislation:C2010C00645:clause:1_45
Version: federal_register_of_legislation:C2010C00645
Segment Type: clause
Provision Reference: sch 1 cl 45
Character Range: 12929–13390

45  Paragraph 136AE(5)(e)
Repeal the paragraph, substitute:
 (e) in the Commissioner's opinion, the derivation of the income or the incurring of the expenditure is attributable, in whole or in part, to activities carried on by the taxpayer:
 (i) at or through the permanent establishment that is referred to in subparagraph (a)(i) or (iii); or
 (ii) in the area covered by the international tax sharing treaty that is referred to in paragraph (a)(ii) or (iv);