Which resident companies qualify?



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Two broad groups qualify to have certain branch profits treated as non-assessable non-exempt income. These are resident companies that either:

  • carry on business through a permanent establishment - for example, a branch - in a listed country or
  • are partners of a partnership - or are presently entitled beneficiaries of a trust - that carries on business through a permanent establishment in a listed country.

Non-assessable non-exempt income treatment does not apply to:

  • resident companies with permanent establishments in unlisted countries
  • resident taxpayers, other than companies, with foreign permanent establishments.
Last modified: 05 Dec 2006QC 17522