Exemption for active business



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The active business exemption exempts you from taxation under the FIF measures for interests you have in foreign companies principally engaged in certain active businesses, known as eligible activities. [section 497]

This exemption also applies when working out:

  • the net income of a trust estate where the trust invests directly in a foreign company engaged in an active business, and
  • the FIF income of a CFC or a CFT - because the income of a CFC or CFT is worked out as though they were a resident taxpayer.

This exemption does not apply to an interest in a non-resident trust.

Last modified: 04 Feb 2010QC 21777