Related Commentary  

133(1)  If this section applies (as to which, see section 132(1)), the special relationship rule is to be read as requiring the taxpayer to show–

(a)the absence of any special relationship, or

(b)as the case may be, the rate or amounts of royalties that would have been payable in the absence of the special relationship.

133(2)  The requirement under subsection (1)(a) includes whichever is applicable of the following requirements.

133(3)  The first of those requirements is–

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