• Items 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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    Country

    Entity

    Kind of income or profit

    Feature of income or profit under tax law of the country

    Canada

    An entity that operates in Canada as an international banking centre under Canadian law

    All passive income and tainted services income

    Not subject to tax in Canada in a tax accounting period

    Canada

    A company that operates in Canada as an investment corporation, or as a mutual fund corporation, under Canadian tax law

    All passive income

    Not taxed in Canada at the normal company tax rate

    France

    A company that operates in France as a soci t  d'investissement   capital variable (SICAV) under French law

    All passive income

    Not subject to tax in France in a tax accounting period

    France

    A company that is treated as a resident of France for the purposes of the tax law of France, and that has elected to be taxed on a tonnage basis rather than on income or profits

    All income or profits

    Not used as the basis for establishing the amount of taxable income, taxable profits, tax base or tax liability of the entity under the tax law of France

    Germany

    A company that is treated as a resident of Germany for the purposes of the tax law of Germany

    All passive income in carrying on business outside Germany at or through a permanent establishment

    Not subject to tax in Germany in a tax accounting period

    Germany

    Either:

    (a) a company that is treated as a resident of Germany for the purposes of the tax law of Germany, or

    (b) any company in carrying on business in Germany at or through a permanent establishment of the company in Germany

    Capital gains in respect of shares in companies

    Not taxed in Germany at the normal company tax rate

    Germany

    A company that is treated as a resident of Germany for the purposes of the tax law of Germany, and that has elected to be taxed on a tonnage basis rather than on income or profits

    All income or profits

    Not used as the basis for establishing the amount of taxable income, taxable profits, tax base or tax liability of the entity under the tax law of Germany

    Japan

    An entity in carrying on business in Japan at or through a permanent establishment of the entity in that country

    All income or profits derived from Japanese governmental bonds

    Not subject to tax in Japan in a tax accounting period

    New Zealand

    Either:

    (a) a company that is treated as a resident of New Zealand for the purposes of the tax law of New Zealand, or

    (b) any entity in carrying on business in New Zealand at or through a permanent establishment of the entity in New Zealand

    Capital gains in respect of tainted assets

    Not subject to tax in New Zealand in a tax accounting period

    United Kingdom of Great Britain and Northern Ireland

    A company that is treated as a resident of the United Kingdom of Great Britain and Northern Ireland for the purposes of the tax law of the United Kingdom of Great Britain and Northern Ireland

    Capital gains in respect of shares in companies where:

    (a) the CGT assets of the companies; or

    (b) the underlying CGT assets of the companies held through one of more non-resident entities that are associates

    include CGT assets having the necessary connection with Australia

    Not subject to tax in the United Kingdom of Great Britain and Northern Ireland in a tax accounting period as a consequence of the substantial shareholding exemption available under the tax law of the United Kingdom of Great Britain and Northern Ireland

    United Kingdom of Great Britain and Northern Ireland

    A company that is treated as a resident of the United Kingdom of Great Britain and Northern Ireland for the purposes of the tax law of the United Kingdom of Great Britain and Northern Ireland, and that has elected to be taxed on a tonnage basis rather than on income or profits

    All income or profits

    Not used as the basis for establishing the amount of taxable income, taxable profits, tax base or tax liability of the entity under the tax law of the United Kingdom of Great Britain and Northern Ireland

    United Kingdom of Great Britain and Northern Ireland

    An entity that operates in the United Kingdom of Great Britain and Northern Ireland as a open-ended investment company under the law of the United Kingdom of Great Britain and Northern Ireland

    All passive income

    Not taxed in the United Kingdom of Great Britain and Northern Ireland at the normal company tax rate

    United States of America

    Either:

    (a) a company that is treated as a resident of the United States of America for the purposes of the tax law of the United States of America, or

    (b) any entity in carrying on business in the United States of America at or through a permanent establishment of the entity in that country

    All income or profits derived from tax-exempt governmental bonds

    Not subject to tax in the United States of America in a tax accounting period

    United States of America

    An entity that operates in the United States of America as a regulated investment company under the tax law of the United States of America

    All passive income

    Not taxed in the United States of America at the normal company tax rate

    Last modified: 05 Dec 2006QC 18000