• Amounts taxed at comparable rates

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    Where a non-resident trust estate is a broad-exemption listed country trust estate-see Chapter 9-in an income year, only distributions from certain concessionally taxed income of the trust estate are subject to the interest charge under section 102AAM. Where a non-resident trust estate is not a broad-exemption listed country trust estate in an income year, distributions made from the income and profits of the trust estate for that year are subject to the interest charge if the amount has not been subject to tax in any listed country in a tax accounting period:

    • ending before the end of the non-resident trust's income year, or
    • commencing during the non-resident trust's income year. [PARAGRAPH 102AAM(1)(b)]

    Before that amount will be exempt from the section 102AAM interest charge on distribution, you will have to show that an amount that was the property of a trust estate was paid to you or applied for your benefit out of accumulated profits which relate to:

    • in the case of a broad-exemption listed country trust estate, income other than eligible designated concession income, or
    • in any other case, income that has been subject to tax in any broad-exemption listed country. [SUBSECTION 102AAM(1A)]
    Last modified: 08 Jun 2005QC 27386