ITAA 1936 s of section 23AH

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

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