DPT provisions definition

DPT provisions meanssections 177H, 177J, 177K, 177L, 177M, 177N, 177P, 177Q and 177R.
Sample 1

Examples of DPT provisions in a sentence

  • GA Res 2749 (XXV), UNGAOR, 25th Sess, Supp No 28, UN Doc A/Res/25/2749, (1970) [Resolution 2749 (XXV)].

  • In addition, the DPT provisions (in combination with Division 145 in Schedule 1 to the Taxation Administration Act 1953) have the object of encouraging significant global entities to provide sufficient information to the Commissioner to allow for the timely resolution of disputes about Australian tax.

  • These provisions, in combination with the DPT provisions, have the object of encouraging significant global entities to provide sufficient information to the Commissioner to allow the timely resolution of disputes about Australian tax.

  • If this phrase is to be maintained, we strongly recommend, that this be ‘turned off’ where there is sufficient information and also an explanation as to its intention – including why it is appropriate for it only to be included in this Section of Part IVA and the perceived issues that the Government are attempting to address.As a matter of principle, the ATO should exhaust all information request avenues before seeking to apply the DPT provisions.

  • The ATO should utilise all information request avenues before seeking to apply the DPT provisions, including the following:• Div.

  • The measure was introduced, so we were informed, to discourage undesirable behaviour by a very limited number of companies but the broad nature of the measures, and the lack of precise targeting, has meant that most large international businesses are potentially caught and it has created a very considerable compliance burden to demonstrate to the UK tax authority, HM Revenue & Customs, that the particular business is outside the DPT provisions.

  • Following the coming into force of the DPT provisions in the FA 2015, on 5th April 2016, HMRC requested additional information relevant to the analysis of the arrangements pursuant to the RSA.

  • The primary objects of the DPT provisions (that is, sections 177H to 177R of the ITAA 1997) are: • to ensure that the Australian tax payable by significant global entities properly reflects the economic substance of the activities that those entities carry on in Australia; and • to prevent those entities from reducing the amount of Australian tax they pay by diverting profits offshore through contrived arrangements between related parties.

  • For the purposes of the DPT provisions, the amount of a DPT tax benefit may be modified if: • the thin capitalisation provisions apply to the relevant taxpayer for the income year; or • the foreign entity is a controlled foreign corporation.

  • The ATO should utilise all information request avenues before seeking to apply the DPT provisions, including the following: Div.

Related to DPT provisions

  • Arrangement Provisions means Part 9, Division 5 of the BCBCA;

  • Relevant Provisions means, in respect of the Determination Agent, the provisions of the Determination Agency Agreement, the Trust Deed, and the Conditions.

  • Supplemental Provisions means these Supplemental Provisions for Federally Funded Contracts, Grants, and Purchase Orders subject to the Federal Funding Accountability and Transparency Act of 2006, As Amended, as may be revised pursuant to ongoing guidance from the relevant Federal or State of Colorado agency or institution of higher education.

  • Grantor Trust Provisions Subpart E of part I of subchapter J of the Code and Treasury Regulations Section 301.7701-4(c).

  • Special Provisions Special Provisions are specific conditions or requirements peculiar to the contract under consideration and are supplemental to the General Provisions. Should the Special Provisions conflict with the General Provisions, the Special Provisions shall prevail.

  • Adjustment Provisions means all relevant provisions of these Conditions which provide for any adjustment, delay, modification, cancellation or determination in relation to an Index, the valuation procedure for an Index or the Preference Shares. This shall include the provisions of Condition 11 (Calculation Agent Modifications) and all subsequent Conditions.

  • statutory provision means a provision of an Act or of an instrument made under an Act.

  • Other Definitional Provisions set forth in Section 1.2 of the Basic Servicing Agreement are incorporated by reference into this 2017-3 Servicing Supplement.

  • Transfer Provisions means the provisions of Section 00-00-000 of the FILOT Act, as amended or supplemented from time to time, concerning, among other things, the necessity of obtaining County consent to certain transfers. Any reference to any agreement or document in this Article I or otherwise in this Fee Agreement shall include any and all amendments, supplements, addenda, and modifications to such agreement or document.

  • Indemnification Provisions means each of the Debtors’ indemnification provisions currently in place whether in the Debtors’ bylaws, certificates of incorporation, other formation documents, board resolutions, or contracts for the current and former directors, officers, managers, employees, attorneys, other professionals, and agents of the Debtors and such current and former directors’, officers’, and managers’ respective Affiliates.

  • Surviving Provisions has the meaning specified in Section 10.02.

  • Subordination Provisions has the meaning specified in Section 8.01(l).

  • REIT Provisions of the Code means Sections 856 through 860 of the Code and any successor or other provisions of the Code relating to real estate investment trusts (including provisions as to the attribution of ownership of beneficial interests therein) and the regulations promulgated thereunder.

  • Specific Redemption Provisions means, with respect to a Special Dividend Period either, or any combination of, (i) a period (a "Non-Call Period") determined by the Board of Directors of the Corporation, after consultation with the Auction Agent and the Broker-Dealers, during which the shares of AMPS subject to such Dividend Period shall not be subject to redemption at the option of the Corporation and (ii) a period (a "Premium Call Period"), consisting of a number of whole years and determined by the Board of Directors of the Corporation, after consultation with the Auction Agent and the Broker-Dealers, during each year of which the shares of AMPS subject to such Dividend Period shall be redeemable at the Corporation's option at a price per share equal to $25,000 plus accumulated but unpaid dividends plus a premium expressed as a percentage of $25,000, as determined by the Board of Directors of the Corporation after consultation with the Auction Agent and the Broker-Dealers.

  • Redemption Provisions Initial Redemption Date: Initial Redemption Percentage: Annual Redemption Percentage Reduction, if any: Repayment Provisions: Optional Repayment Date(s):

  • Standard Provisions mean these Standard Provisions that form a part of the Certificate of Designations relating to the Designated Preferred Stock.

  • General Provisions means those portions of the Subscription Agreement headed “General Provisions” and contained on pages 7 to 12;

  • Spendthrift provision means a term of a trust that restrains both voluntary and involuntary transfer of a beneficiary's interest.

  • provisions means "provisions, terms, agreements, covenants and/or conditions"; (iii) "lien" shall mean "lien, charge, encumbrance, title retention agreement, pledge, security interest, mortgage and/or deed of trust"; (iv) "obligation" shall mean "obligation, duty, agreement, liability, covenant and/or condition"; (v) "any of the Leased Premises" shall mean "the Leased Premises or any part thereof or interest therein"; (vi) "any of the Land" shall mean "the Land or any part thereof or interest therein"; (vii) "any of the Improvements" shall mean "the Improvements or any part thereof or interest therein"; (viii) "any of the Equipment" shall mean "the Equipment or any part thereof or interest therein"; and (ix) "any of the Adjoining Property" shall mean "the Adjoining Property or any part thereof or interest therein".

  • Additional Provisions shall have the meaning set forth in Section 15.01.

  • former provisions means the provisions of the Petroleum Act 1936 which, by force of section 134 of the Petroleum Act are deemed to subsist and enure in their application to or in relation to the Xxxxxx Island Lease;

  • Agreement Date Provisions means Part 1 (Introduction), Part 2 (Term), Part 3 (Conditions Precedent and Milestone Requirement), Condition 8 (Application), Condition 9 (Definitions: Part 5A), Condition 14 (Strike Price Adjustments), Condition 16 (Application), Condition 17 (Definitions: Part 5B), Condition 20 (Strike Price Adjustments), Condition 24 (Default Interest), Condition 25 (Set-off), Condition 26 (Deductions and withholdings), Condition 27 (Payment accounts), Condition 28 (Generator representations and warranties), Condition 29 (CfD Counterparty representations and warranties), Condition 30 (Generator undertakings: General), Condition 32 (Generator undertakings: Information provision and no cumulation of Subsidy, state aid and/or union funding), Part 12 (Termination), Part 14 (Dispute Resolution) to Part 17 (Miscellaneous) (inclusive), Schedule 1 (Conditions Precedent), Annex 1 (Calculation of Termination Amount), Annex 2 (Change Control Procedure), Annex 3 (Form of Direct Agreement), paragraph 1 of Part A of Annex 7 (FMS arrangements, Sustainability Criteria, RQM Calculation Methodology and ACT Efficiency) and Annex 8 (Pro forma notices);

  • Optional Deferral Provision means, as to any Qualifying Capital Securities, a provision in the terms thereof or of the related transaction agreements to the effect that:

  • Restrictive Covenant Agreement means any agreement, and any attachments or schedules thereto, entered into by and between the Participant and the Partnership or its Affiliates, pursuant to which the Participant has agreed, among other things, to certain restrictions relating to non-competition (if applicable), non-solicitation and/or confidentiality, in order to protect the business of the Partnership and its Affiliates.

  • Restrictive Covenant Agreements is defined in the Recitals.

  • Exceptions and Limitations means fair use, fair dealing, and/or any other exception or limitation to Copyright and Similar Rights that applies to Your use of the Licensed Material.