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  • Introduction



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    Part 8A of the regulations and associated schedules deal with the taxation of foreign source income. The provisions:

    • declare those countries that are to be treated as broad-exemption or limited-exemption listed
    • provide that Swiss Cantonal taxes are to be treated as Federal taxes
    • specify when capital gains are taken to have been subject to tax for the purposes of the CFC measures, the transferor trust measures and the non-assessable non-exempt income treatment of branches of Australian companies in listed countries
    • contain rules for determining whether an amount is designated concession income
    • set out the accruals taxation laws of other countries that are recognised for the purposes of providing relief from double accruals taxation.
    Last modified: 05 Dec 2006QC 17522