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Edited version of private advice
Authorisation Number: 1051514738787
Date of advice: 9 May 2019
Ruling
Subject: Withholding tax - Managed investment trust - Foreign resident
Question
Is the entity an entity of the kind specified in paragraph 275-20(4)(f) of the ITAA 1997?
Answer
No.
This ruling applies for the following period:
1 January 20XX to 31 December 20XX.
The scheme commences on:
1 January 20XX
Relevant facts and circumstances
The entity is not subject to any foreign collective investment regime.
The entity is not recognised as being used for collective investment.
Relevant legislative provisions
Section 275-20 Income Tax Assessment Act 1997
Reasons for decision
The entity's business does not fall within the definition of collective investment regime in the foreign country where the entity is subject to regulation.
Conclusion
The entity is not an entity of the kind specified in paragraph 275-20(4)(f) as it is not recognised under a foreign law as being used for collective investment.