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Cross-border transfer pricing guidance

             (1)  For the purpose of determining the effect this Subdivision has in relation to an entity:

                     (a)  work out whether an entity gets a * transfer pricing benefit consistently with the documents covered by this section, to the extent the documents are relevant; and

                     (b)  interpret a provision of an * international tax agreement consistently with those documents, to the extent they are relevant.

             (2)  The documents covered by this section are as follows:

                     (a)  the Model Tax Convention on Income and on Capital, and its Commentaries, as adopted by the Council of the Organisation for Economic Cooperation and Development and last amended on 22 July 2010;

                     (b)  the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, as approved by that Council and last amended on 22 July 2010;

                     (c)  a document, or part of a document, prescribed by the regulations for the purposes of this paragraph.

             (3)  However, a document, or a part of a document, mentioned in paragraph (2)(a) or (b) is not covered by this section if the regulations so prescribe.

             (4)  Regulations made for the purposes of paragraph (2)(c) or subsection (3) may prescribe different documents or parts of documents for different circumstances.

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