House of Representatives

Taxation Laws Amendment (Foreign Income Measures) Bill 1997

Explanatory Memorandum

(Circulated by authority of the Treasurer, the Hon Peter Costello, MP)

Appendix B

Note
- Active income not subject to tax in a listed country and derived by a CFC resident in a listed country from sources outside that country is taxed on an accruals basis under the CFC measures to ensure that low taxed profits are not repatriated to Australia as exempt dividends. Amounts of adjusted tainted income derived by a CFC resident in a broad-exemption listed country from sources outside that country will also be taxed on an accruals basis if they are not subject to tax in a broad-exemption listed country.


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