Income tax: foreign tax credit system: issues relating to the practical application of section 23AG

TR 96/15 deals with issues relating to the practical application of section 23AG, including whether temporary absences form part of a period of foreign service.

It continues to apply to arrangements begun to be carried out before the withdrawal but does not apply to arrangements begun to be carried out after the withdrawal.

The arrangements dealt with in TR 96/15 are now covered by Taxation Determination TD 2012/8 , which issued today.