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  • Section 3 - Is the CFC's income generally exempt from accruals taxation?

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    A number of exemptions from accruals taxation are provided for amounts taxed in a comparable tax country listed in the Income Tax Regulations. Before 1 July 1997, the same list was also used to provide exemptions under the foreign tax credit system. There are now separate lists for the exemptions.

    Countries listed for accruals taxation purposes are called broad-exemption listed countries. These countries are listed in part 1 of attachment A in appendix 1. Countries not listed for accruals taxation purposes are called non-broad-exemption listed countries.

    Countries listed for the purposes of the foreign tax credit system but not for accruals taxation purposes are called limited-exemption listed countries. These countries are listed in part 2 of attachment A in appendix 1. Countries on either the broad-exemption or limited-exemption lists are treated as listed for the purposes of the foreign tax credit system. Countries not on either list are called unlisted countries.

    Last modified: 05 Dec 2006QC 17522