Disclaimer This edited version has been archived due to the length of time since original publication. It should not be regarded as indicative of the ATO's current views. The law may have changed since original publication, and views in the edited version may also be affected by subsequent precedents and new approaches to the application of the law. You cannot rely on this record in your tax affairs. It is not binding and provides you with no protection (including from any underpaid tax, penalty or interest). In addition, this record is not an authority for the purposes of establishing a reasonably arguable position for you to apply to your own circumstances. For more information on the status of edited versions of private advice and reasons we publish them, see PS LA 2008/4. |
Edited version of private advice
Authorisation Number: 1051578990503
Date of Advice:
Date of advice: 26 September 2019
Ruling
Subject: Foreign branch income of resident company
The Commissioner was asked a question in relation to whether income derived by a resident company is non-assessable non-exempt income pursuant to subsection 23AH(2) of the Income Tax Assessment Act 1936.
The Commissioner has ruled on the question.