Published on 31 Oct 08
by THE TAX INSTITUTE
We refer to Draft Taxation Determination TD 2008/D13 (“Draft TD”). The Draft TD considers when foreign income tax will be imposed on the partners, not the limited partnership, under s.830-10(1)(b) of the Income Tax Assessment Act 1997 (“Act”) for the purpose of determining whether a foreign limited partnership is a foreign hybrid limited partnership under Division 830 of the Act.
NATIONAL INSTITUTE OF ACCOUNTANTS
TAXATION INSTITUTE OF AUSTRALIA