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Legislation
ATO documents that consider ITAA 1936 s 121D(6)
8 documents
Income tax: Offshore Banking Units (OBU) - if an OBU acts as funds manager for a trust with offshore investors and an Australian trustee, does the funds management role fall within the definition of an investment activity under subsection 121D(6)?
Income tax: Offshore Banking Units (OBU) - does the definition of advisory activity in section 121D(7) encompass advising an offshore debt investor or offshore borrower in an offshore leveraged lease which has an Australian end-user?
Offshore Banking Unit: Investment advice on behalf of a foreign permanent establishment of an Australian resident
Offshore Banking Unit: Apportioning trust management fees from portfolio investment activity
Offshore Banking Units: Investment Activity
Offshore banking unit: investment made with an offshore person or a non-resident
Income tax: Offshore Banking Units (OBU) - if an OBU acts as funds manager for a trust with offshore investors and an Australian trustee, does the funds management role fall within the definition of an investment activity under subsection 121D(6)?
Income tax: Offshore Banking Units (OBU) - does the definition of advisory activity in section 121D(7) encompass advising an offshore debt investor in an offshore leveraged lease which has an Australian end-user?