28 Sep 06 Interest withholding tax - cross-border interbranch funds transfers within resident ADIs - TR 2006/9This final Taxation Ruling was issued on 27 September 2006. It was previously released in draft form as TR 2005/D18: see 2005 TAXVINE No 50 (21) (16 December 2005). Its full title is "Income tax: interest withholding tax - cross-border interbranch funds transfers within resident authorised deposit-taking institutions".
The Ruling addresses the withholding tax liability of a non-resident that is paid interest by an authorised deposit-taking institution (ADI) that is an Australian resident. It contains the Commissioner's opinion on the way in which s 128B of Division 11A of Part III of ITAA 1936 applies to interest paid to non-residents by resident ADIs. In particular, the Ruling focuses on the application of subparagraph (i) of s 128B(2)(b).
For a copy of TR 2006/9, go here