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34 documents
Offshore Banking Unit: Investment advice on behalf of a foreign permanent establishment of an Australian resident
Offshore Banking Unit: Apportioning trust management fees from portfolio investment activity
Offshore Banking Units: Investment Activity
Offshore Banking Units: Application of paragraph 128AE(2)(d) to the head company of a consolidated group
Offshore Banking Units: Application of paragraph 128AE(2)(ba) to wholly owned non-bank subsidiaries of non-bank OBUs
Offshore banking units: trading activity
Offshore banking unit: investment made with an offshore person or a non-resident
Income tax: can Part IVA of the Income Tax Assessment Act 1936 apply to an asymmetric swap scheme?
Income tax: Offshore Banking Units - what is the meaning of 'guarantee-type activity' under subsection 121D(3)?
Income tax: Offshore Banking Units - does the OBU concessional tax regime apply to assessable income derived after 30 June 1992 where the OB activities were entered into by an OBU prior to 1 July 1992?
Income tax: Offshore Banking Units - if an entity is registered as an OBU and that entity conducts both offshore banking activities and domestic banking activities, can the OBU trade in foreign currency with the domestic part of the bank (the 'domestic part')?
Income tax: Offshore Banking Units - is an OBU entitled to concessional tax treatment for income from OB activities which were entered into prior to the entity being registered as an OBU?
Income tax: Offshore Banking Units - can a sub-subsidiary of a bank be registered as an OBU?
Income tax: Offshore Banking Units - what is the effect of a transaction which falls within the definition of offshore banking activity, which is entered into by the part of an OBU which handles the domestic (as opposed to offshore) activities of the bank and which is accounted for in the domestic books?
Income tax: Offshore Banking Units - if a loan entered into by a foreign branch of an Australian resident bank is assigned to the Australian OBU head office, does this constitute an OB activity?
Income tax: Offshore Banking Units (OBU) - can an OBU use offshore banking (OB) money (ie money that is not non-OB money) for purposes other than OB activities and replace those funds at a later date?
Income tax: Offshore Banking Units (OBU) - does share capital subscribed by a resident owner to its subsidiary, before that subsidiary becomes registered as an OBU, constitute 'OBU resident-owner money'?
Income tax: Offshore Banking Units (OBU) - where a non-resident has an Australian branch and an Australian subsidiary, and the subsidiary is registered as an OBU, does any share capital subscribed in the subsidiary by the parent fall within the definition of 'non-OB money'?
Income tax: Offshore Banking Units (OBU) - does trading in, or entering into commodity derivatives such as commodity futures, forwards, options and swaps constitute offshore banking (OB) activity for the purposes of section 121D?
Income tax: Offshore Banking Units (OBU) - if an OBU carries on a business of trading in shares or debt instruments, such that the trading is an offshore banking (OB) activity for the purposes of subsection 121D(1), are dividends and interest derived from holding the shares or debt instruments assessable OB income?