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  • Part 2 - Taxation of branch profits



    This information may not apply to the current year. Check the content carefully to ensure it is applicable to your circumstances.

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    Foreign branch income of a resident company that is not assessable

    Which resident companies qualify?

    Two broad groups qualify to have certain branch profits treated as non-assessable non-exempt income. These are resident companies that either:

    • carry on business through a permanent establishment - for example, a branch, or
    • are partners of a partnership - or are presently entitled beneficiaries of a trust - and that partnership or trust carries on business through a permanent establishment.

    Non-assessable non-exempt income treatment does not apply to resident taxpayers, other than companies, with foreign permanent establishments.

    Last modified: 05 Dec 2006QC 18000