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.
Philip is a barrister at the Victorian Bar practising in federal and state taxation and superannuation. He acts for both taxpayers and revenue authorities and has appeared in a number of leading cases in these fields. Philip is also the author of Bender’s Australian Stamp Duties, a book published by The Tax Institute dealing with stamp duty in all Australian jurisdictions.
- Current at
26 June 2019