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
|
A company that is treated as a resident of the United Kingdom for the purposes of the tax law of the United Kingdom
|
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 in a tax accounting period as a consequence of the substantial shareholding exemption available under the tax law of the United Kingdom
|
United Kingdom
|
A company that is treated as a resident of the United Kingdom for the purposes of the tax law of the United Kingdom, 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
|
United Kingdom
|
An entity that operates in the United Kingdom as a open-ended investment company under the law of the United Kingdom
|
All passive income
|
Not taxed in the United Kingdom at the normal company tax rate
|
United States
|
Either:
(a) a company that is treated as a resident of the United States for the purposes of the tax law of the United States, or
(b) any entity in carrying on business in the United States 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 in a tax accounting period
|
United States
|
An entity that operates in the United States as a regulated investment company under the tax law of the United States
|
All passive income
|
Not taxed in the United States at the normal company tax rate
|