ITAA 1936 s 23AH(2)

Income tax: is an amount that is a cost in relation to a debt interest covered by paragraph 820-40(1)(a) of the Income Tax Assessment Act 1997 (ITAA 1997) deductible under section 25-90 of the ITAA 1997 (or, alternatively, under subsection 230-15(3) of the ITAA 1997) where that amount is incurred in earning income that meets the requirements of both section 23AH of the Income Tax Assessment Act 1936 and section 768-5 of the ITAA 1997?

Non-assessable non-exempt income: periodic payments received under a swap arrangement

Foreign income - non-assessable and non-exempt: substantial equipment permanent establishment in a listed country

Section 23AH of the Income Tax Assessment Act 1936 and drilling rig deployed outside the exclusive economic zone (EEZ) of a foreign country

Permanent Establishment of a US Limited Liability Company

Income tax: is an amount that is a cost in relation to a debt interest covered by paragraph 820-40(1)(a) of the Income Tax Assessment Act 1997 (ITAA 1997) deductible under section 25-90 of the ITAA 1997 (or, alternatively, under subsection 230-15(3) of the ITAA 1997) where that amount is incurred in earning income that meets the requirements of both section 23AH of the Income Tax Assessment Act 1936 and section 768-5 of the ITAA 1997?

Income tax: satisfying the 'carrying on a business at or through a permanent establishment' requirement in section 23AH where a company is taken to have a permanent establishment (PE) in relation to substantial equipment

Non-portfolio dividend received by a taxpayer through its permanent establishment in Hong Kong

Permanent establishment of a US Limited Liability Company

Assessability of foreign branch income derived from New Zealand

Assessability of foreign branch income derived from New Zealand

Application of subsection 23AH(2): deemed permanent establishment (PE) and carrying on of business - Article 5.4 of the 1995 New Zealand Agreement