Active income test, example 2

UK Co is a resident of a listed country, an 'open-ended investment company' under UK law and 100% owned by an Australian entity. UK Co derives $1 million rental income from an unrelated party from property located in another country. The rental income is not taxed in the UK or in any other listed country. UK Co does not derive any other income. The de minimis test and the active income test will not be satisfied. The income will be 'adjusted tainted income' and will be 'eligible designated concession income'. UK Co has attributable income of $1 million.

Further Information

For more information refer to Chapter 1 Part 3Foreign income return form guide 2010-11.

End of further information
    Last modified: 21 Feb 2012QC 25356