Commonwealth Consolidated Acts Commonwealth Consolidated Acts(1) The Commissioner may make a determination mentioned in subsection 815 - 30(1), in writing, for the purpose of negating a * transfer pricing benefit an entity gets.
Treaty requirement
(2) However, this section only applies to an entity if:
(a) the entity gets the * transfer pricing benefit under subsection 815 - 15(1) at a time when an * international tax agreement containing an * associated enterprises article applies to the entity; or
(b) the entity gets the transfer pricing benefit under subsection 815 - 15(2) at a time when an international tax agreement containing a * business profits article applies to the entity.
Note: This Subdivision does not apply to income years to which Subdivisions 815 - B and 815 - C apply: see section 815 - 1 of the Income Tax (Transitional Provisions) Act 1997 .