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A non-resident trust estate is a broad-exemption listed country trust estate in an income year if all of the income or profits derived by the trust estate during that income year are either:
- subject to tax in one or more broad-exemption listed countries in a tax accounting period ending before the end of, or commencing during, the income year or
- designated concession income in relation to any broad-exemption listed country.
A non-resident trust estate could be treated as a resident of a non-broad-exemption listed country under that country's tax laws - for example, the trustee may be a resident of that country. However, for the purposes of the transferor trust measures, the trust would be treated as a broad-exemption listed country trust estate if all of the trust's income is derived from one or more broad-exemption listed countries and is subject to tax in those countries.
Last modified: 05 Dec 2006QC 17522