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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