Legislation

ITAA 1936 s 23AH and section 23AJ and the New International Tax Arrangements (Participation Exemption and Other Measures) Bill 2004 which significantly amended these sections, expressly provided that section 23AH could apply where the profits passed through an interposed partnership or trust to the Australian resident company from the foreign company (former section 23AH(3) and current section 23AH(10)

ATO documents that consider ITAA 1936 s 23AH and section 23AJ and the New International Tax Arrangements (Participation Exemption and Other Measures) Bill 2004 which significantly amended these sections, expressly provided that section 23AH could apply where the profits passed through an interposed partnership or trust to the Australian resident company from the foreign company (former section 23AH(3) and current section 23AH(10)