The Australian government today released guidance further clarifying the Multinational Anti-Avoidance Law (MAAL), which is designed to shut down schemes by foreign entities to avoid taxable presence in Australia thereby avoiding the attribution of business profits there.
The new tax determination, TD 2018/12 , further elaborates on the terms ‘directly in connection with,’ contained in subparagraph 177DA(1)(a)(ii) of the Income Tax Assessment Act 1936.
The guidance bears a January 1, 2016, effective date which is the effective dates of the MAAL.
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