Introduction
Part 8A of the Income Tax Regulations 1936, and associated schedules, deal with the taxation of foreign source income. The provisions:
- declare those countries that are to be treated as listed, unlisted and section 404 countries
- provide that Swiss cantonal taxes are treated as if they were federal taxes
- contain rules for determining whether an amount is designated concession income
- specify when the capital gains are taken to have been subject to tax for the purpose of the controlled foreign company (CFC) measures, the transferor trust measures, and the non-assessable non-exempt treatment of foreign branches of Australian companies, and
- set out the accruals taxation laws of other countries that are recognised for the purpose of providing relief from double accruals taxation.