The transferor trust measures operate to accruals tax residents of Australia who have transferred property or services to a non-resident trust estate on certain profits derived by the trust.
Related measures also operate to impose an interest charge on certain trust distributions from non-resident trusts that are included in the assessable income of a resident beneficiary. Broadly, the interest charge applies if the profits of the trust from which the distribution was made were not subject to tax:
- in a listed country, or
- because of attribution under the transferor trust provisions.
See the glossary at the start of this guide to find the meaning of certain words and expressions used in this chapter.
Are you subject to the transferor trust measures?
Interest charge for beneficiaries of non-resident trust estates