ITAA 1936 s X

OECD hybrid mismatch rules - targeted integrity rule

Central management and control test of residency: identifying where a company's central management and control is located

Compendium

Treatment of non-resident captive insurance arrangements

Income tax: does section 103-20 of the Income Tax Assessment Act 1997 apply in determining the capital gain or loss content of attributable income of a controlled foreign company?

Income tax: how is double taxation avoided in the following situations where a Controlled Foreign Company (CFC) pays a dividend to an attributable taxpayer:(a) Out of income or profits derived by the CFC during a statutory accounting period that are subject to attribution and paid after the end of the CFC's statutory accounting period but before the end of the attributable taxpayer's year of income? (b) Out of income or profits derived by the CFC during a statutory accounting period that are subject to attribution and paid both before the end of the CFC's statutory accounting period and the attributable taxpayer's year of income?

Income tax: which country is for the purposes of Part X of the Income Tax Assessment Act 1936 (the Act) the country of residence of a UK Limited Partnership (LP), a US LP, a UK Limited Liability Partnership (LLP) and a US LLP being a non-resident corporate limited partnership within Part III Division 5A of the Act?

Income tax: if an 'attributable taxpayer' makes a choice under item 4 of the table in subsection 960-60(1) of Subdivision 960-D of the Income Tax Assessment Act 1997, to use the 'applicable functional currency', will this choice apply to its calculation of 'attribution surplus' under section 370 of Part X of the Income Tax Assessment Act 1936?

Income tax: can a 'small proprietary company', not required to prepare reports under section 292 of the Corporations Act 2001 , make a choice to use the 'applicable functional currency' under item 1 of the table in subsection 960-60(1) of the Income Tax Assessment Act 1997 ?

Income tax: are the active assets of a partnership, in which a foreign company is a partner, active foreign business assets of the foreign company for the purposes of the capital gains tax participation exemption provisions contained in Subdivision 768-G of the Income Tax Assessment Act 1997?

Compendium

Income tax: when is 'foreign income tax... imposed... on the partners, not the partnership' under paragraph 830-10(1)(b) of the Income Tax Assessment Act 1997 for the purpose of determining whether a foreign limited partnership is a foreign hybrid limited partnership under Division 830 of that Act?

Income tax: in the definition of 'financial intermediary business' what is meant by 'a business whose income is principally derived from the lending of money'?

Compendium

Income tax: foreign income: is a lump sum payment received by a controlled foreign company (CFC), as consideration for the assignment of an interest stream, passive income for the purposes of Part X of the Income Tax Assessment Act 1936 (the Act)?

Income tax: international transfer pricing - cost contribution arrangements

Income tax: entitlement to foreign income tax offsets under section 770-10 of the Income Tax Assessment Act 1997 where income is derived from investing in fiscally transparent foreign entities

First home super saver scheme

Income tax: research and development tax incentive: membership funding for the ACA Low Emissions Technologies Program

Income tax: research and development tax incentive: membership funding for the ACA Low Emissions Technologies Program