Attachment B - Specific types of designated concession income

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This information may not apply to the current year. Check the content carefully to ensure it is applicable to your circumstances.

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Amounts derived by the following entities are treated as designated concession income:

• an entity that operates in Canada as an international banking centre under a law of Canada
• an entity that operates in Canada as a non-resident owned investment corporation under a law of Canada
• an entity that operates in France as a headquarters or coordination entity, or as a logistics centre under a law of France or by virtue of an administrative arrangement with the French authorities
• an entity that operates in France as a soci t  d'investissement   capital variable (SICAV) or as a soci t  de capital risque (SCR) under a law of France
• an entity that operates in Germany as a headquarters or coordination entity under a law of Germany or by virtue of an administrative arrangement with the German authorities.

Amounts derived by the following entities and from the following activities are treated as designated concession income for statutory accounting periods of CFCs commencing before 1 July 1997.

Belgium

• Coordination centres
• Foreign sales corporations
• Distribution centres

Brazil

• Authorised investment funds

Bulgaria

• Entities in duty free zones

France

• Headquarters of foreign companies

Germany, Federal Republic of

• Management centres (Kontrollstellenerlass)

Greece

• Offshore companies

Hungary

• Banking activities of foreign financial institutions

Ireland, Republic of

• Income - including income from financial services and shipping - taxed at 10%
• Headquarters operations

Israel

• Foreign international trade companies

Luxembourg

• Holding companies
• Re-insurance business
• Coordination centres

Malaysia

• Inward re-insurance business
• Offshore insurance income
• Operational headquarters

Malta

• Offshore activities

Netherlands

• Headquarters of foreign companies
• Foreign sales corporation

Pakistan

• Air transport operations

Philippines

• Regional headquarters of multinational companies
• Offshore banking units
• Foreign currency deposit units

Portugal

• Madeira and Azores tax free zones

Singapore

• Asian currency units
• Approved securities companies
• Insurance and re-insurance of risks outside Singapore
• Gold bullion, gold features and financial futures
• Syndicated offshore credit and underwriting facilities
• Operational headquarters
• Offshore managed funds
• Oil futures concession

Solomon Islands

• Air transport operations
• Insurance business

Spain

• Headquarters of foreign companies
• Venture capital companies and funds

Sri Lanka

• Offshore banking services
• Income from services rendered outside Sri Lanka

Switzerland

• Holding companies
• Service or auxiliary companies
• Domiciliary companies
• Participation exemption

Tonga

• Offshore banking

Turkey

• Export incentives, including international transport earnings

Western Samoa

• International offshore centres