(1) The object of this Subdivision is to ensure that the amount brought to tax in Australia from cross - border conditions between entities is not less than it would be if those conditions reflected:
(a) the arm's length contribution made by Australian operations through functions performed, assets used and risks assumed; and
(b) the conditions that might be expected to operate between entities dealing at * arm's length.
(2) The Subdivision does this by specifying that, where an
entity would otherwise get a tax advantage from actual conditions that differ
from * arm's length conditions, the arm's length conditions are taken
to operate for income tax and withholding tax purposes.