The application of Division 13 by the Commissioner merely requires; a supply or acquisition of property (defined to include services) under an international agreement (broadly defined) between two or more parties; that the Commissioner be satisfied that the parties to the transaction were not dealing at arm &apos; s length; and, that the Commissioner exercise his discretion to apply it.
The application of Division 13 by the Commissioner merely requires; a supply or acquisition of property (defined to include services) under an international agreement (broadly defined) between two or more parties; that the Commissioner be satisfied that the parties to the transaction were not dealing at arm &apos; s length; and, that the Commissioner exercise his discretion to apply it.