They should be institutionalised: the AFI exemptions in Australia’s CFC legislation
Publication date: 01 Jun 07
Source: "THE TAX SPECIALIST" JOURNAL ARTICLE
Abstract:
Australia's Controlled Foreign Company regime is aimed at the accruals taxation of certain income derived by foreign companies. Ordinarily, certain interest income and income and gains derived in respect of financial instruments would be taxed on an accruals basis under this regime. However, there are certain exemptions from the accruals taxation of such income for subsidiaries of Australian Financial Institutions. This article examines the mechanisms of these exemptions and outlines a proposal for reform of these exemptions.
Author profile:
Dr Philip BenderPhilip Barrister at Law, Victorian Bar has many years experience in advising on international tax, including structuring of managed funds and other inbound and outbound investments. Philip advises and appears regularly for taxpayers and the Commissioner in both the AAT and Federal Court, including on international tax matters. He also appears in commercial and trust matters in State Courts. Philip is also a contributing author to 2 books (Taxation of Financial Arrangements and Business Tax Reform in Prospect and Retrospect) and has published numerous articles on international tax issues.
Current at 26 August 2011
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