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On 2 June 2010, the ATO released for public comment by 30 July 2010 draft Taxation Ruling TR 2010/D2 entitled "Income tax: application of the transfer pricing provisions to business restructuring by multinational enterprises".

The draft Ruling set outs the Commissioner's views on the application of Australia's transfer pricing provisions in Division 13 of Part III of ITAA 1936 and the Associated Enterprises Article of Australia's tax treaties (treaty Article 9) of the International Agreements Act 1953 to business restructuring arrangements.


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