For the purposes of the definition of 'International related parties', means an interest in equity, voting rights, or income distribution of 20% or greater.
International related parties
International related parties are persons who are parties to international dealings that can be subject to section 136AD of the ITAA 1936 or associated enterprises article of a relevant double tax agreement (DTA). The term includes:
- any overseas entity or person who participates directly or indirectly in your management, control or capital
- any overseas entity or person in respect of which you participate directly or indirectly in the management, control or capital
- any overseas entity or person in respect of which persons who participate directly or indirectly in its management, control or capital are the same persons who participate directly or indirectly in your management, control or capital.
International related party dealings
Means international transactions, agreements or arrangements between related parties; for example, an agreement with your foreign subsidiary. The term includes all transactions between an Australian resident and international related parties.
Life insurance policy
Has the meaning given to the expression life policy in the Life Insurance Act 1995 but includes both of the following:
- a contract made in the course of carrying on business that is a life insurance business because of a declaration in force under section 12A or 12B of that Act
- a sinking fund policy within the meaning of that Act.
Includes a right of participation, the exercise of which is contingent on an agreed event occurring.
Has the same meaning as in subsection 6(1) of the ITAA 1936 and section 995-1 of the ITAA 1997.
Are tax jurisdictions of interest as listed in Appendix 1.