P$,$ A company incorporated in the US$,$ is in the business of providing onlinecloud services. It has a subsidiary in Australia, A$,$ which promotes and liaiseswith customers in the country. It also negotiates the terms of contracts withcustomers in Australia. The finalised contracts are entered into between thecustomers and another subsidiary in Singapore, S$.$ The two subsidiaries haveentered into a service agreement under which A provides the marketing servicesas well as after$-$sale supporting services to S for a service fee calculated on acost plus basis. S has entered into similar agreements with P$$s subsidiaries inother Asian countries. Discuss whether the structure may be subject to Pt IVA, including the argumentsthat the group may put forward to support its position.