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They should be institutionalised: the AFI exemptions in Australia’s CFC legislation
Published on 01 Jun 07 by "THE TAX SPECIALIST" JOURNAL ARTICLE
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.