Taxation Determination
TD 92/187
Income tax: insurance: is foreign income remitted to Australia for the purposes of the former section 112B if it is credited in foreign currency to a life assurance company's bank account in Australia?
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Please note that the PDF version is the authorised version of this ruling.
FOI status:
may be releasedFOI number: I 1213638| This Determination, to the extent that it is capable of being a 'public ruling' in terms of Part IVAAA of the Taxation Administration Act 1953, is a public ruling for the purposes of that Part. Taxation Ruling TR 92/1 explains when a Determination is a public ruling and how it is binding on the Commissioner. Unless otherwise stated, this Determination applies to years commencing both before and after its date of issue. |
1. Yes. Foreign income is remitted to Australia when it becomes available to the life assurance company in Australia. Under current banking practices in Australia, once an amount of foreign income is credited to a bank account in Australia, that income is available in Australia even though the bank account is denominated in a foreign currency.
Commissioner of Taxation
12/11/92
Previously issued as Draft TD 92/D134
References
ATO references:
NO Insurance Industry Cell
Related Rulings/Determinations:
TD 92/117
TD 92/118
TD 92/121
Subject References:
Australian life assurance companies
foreign income remitted
foreign currency bank accounts
Legislative References:
ITAA 112B