Income tax: Offshore Banking Units - can a sub-subsidiary of a bank be registered as an OBU?
1
Yes, but only where the subsidiary and sub-subsidiary are wholly owned by a bank which is registered as an offshore banking unit (OBU). [1]
2
Section 128AE of the Income Tax Assessment Act 1936 lists the entities which may be registered as OBUs: . savings and trading banks . State banks . financial institutions authorised to deal in foreign exchange . wholly owned subsidiaries of banks registered as OBUs
3
It is not necessary for the interposed entity to be a bank or an OBU so long as all of the shares are ultimately beneficially owned by a bank registered as an OBU.