Foreign branch income of a resident company that is not assessable
Which resident companies qualify?
Two broad groups qualify to have certain branch profits treated as non-assessable non-exempt income. These are resident companies that either:
- carry on business through a permanent establishment - for example, a branch, or
- are partners of a partnership - or are presently entitled beneficiaries of a trust - and that partnership or trust carries on business through a permanent establishment.
Non-assessable non-exempt income treatment does not apply to resident taxpayers, other than companies, with foreign permanent establishments.