Attachment B

Last updated 1 August 2019

Items of designated concession income
Country	Entity	Kind of income or profit	Feature of income or profit under tax law of the country
Canada	An entity that operates in Canada as an international banking centre under Canadian law	All passive income and tainted services income	Not subject to tax in Canada in a tax accounting period
Canada	A company that operates in Canada as an investment corporation, or as a mutual fund corporation, under Canadian tax law	All passive income	Not taxed in Canada at the normal company tax rate
France	A company that operates in France as a société d'investissement à capital variable (SICAV) under French law	All passive income	Not subject to tax in France in a tax accounting period
France	A company that is treated as a resident of France for the purposes of the tax law of France, and that has elected to be taxed on a tonnage basis rather than on income or profits	All income or profits	Not used as the basis for establishing the amount of taxable income, taxable profits, tax base or tax liability of the entity under the tax law of France
Germany	A company that is treated as a resident of Germany for the purposes of the tax law of Germany	All passive income in carrying on business outside Germany at or through a permanent establishment	Not subject to tax in Germany in a tax accounting period
Germany	Either: (a) a company that is treated as a resident of Germany for the purposes of the tax law of Germany, or (b) any company in carrying on business in Germany at or through a permanent establishment of the company in Germany	Capital gains in respect of shares in companies	Not taxed in Germany at the normal company tax rate
Germany	A company that is treated as a resident of Germany for the purposes of the tax law of Germany, and that has elected to be taxed on a tonnage basis rather than on income or profits	All income or profits	Not used as the basis for establishing the amount of taxable income, taxable profits, tax base or tax liability of the entity under the tax law of Germany
Japan	An entity in carrying on business in Japan at or through a permanent establishment of the entity in that country	All income or profits derived from Japanese governmental bonds	Not subject to tax in Japan in a tax accounting period
New Zealand	Either: (a) a company that is treated as a resident of New Zealand for the purposes of the tax law of New Zealand, or (b) any entity in carrying on business in New Zealand at or through a permanent establishment of the entity in New Zealand	Capital gains in respect of tainted assets	Not subject to tax in New Zealand in a tax accounting period
United Kingdom of Great Britain and Northern Ireland	A company that is treated as a resident of the United Kingdom of Great Britain and Northern Ireland for the purposes of the tax law of the United Kingdom of Great Britain and Northern Ireland	Capital gains in respect of shares in companies where: (a) the CGT assets of the companies, or (b) the underlying CGT assets of the companies held through one of more non-resident entities that are associates include CGT assets having the necessary connection with Australia	Not subject to tax in the United Kingdom of Great Britain and Northern Ireland in a tax accounting period as a consequence of the substantial shareholding exemption available under the tax law of the United Kingdom of Great Britain and Northern Ireland
United Kingdom of Great Britain and Northern Ireland	A company that is treated as a resident of the United Kingdom of Great Britain and Northern Ireland for the purposes of the tax law of the United Kingdom of Great Britain and Northern Ireland, and that has elected to be taxed on a tonnage basis rather than on income or profits	All income or profits	Not used as the basis for establishing the amount of taxable income, taxable profits, tax base or tax liability of the entity under the tax law of the United Kingdom of Great Britain and Northern Ireland
United Kingdom of Great Britain and Northern Ireland	An entity that operates in the United Kingdom of Great Britain and Northern Ireland as an open-ended investment company under the law of the United Kingdom of Great Britain and Northern Ireland	All passive income	Not taxed in the United Kingdom of Great Britain and Northern Ireland at the normal company tax rate
United States	Either: (a) a company that is treated as a resident of the United States for the purposes of the tax law of the United States, or (b) any entity in carrying on business in the United States at or through a permanent establishment of the entity in that country	All income or profits derived from tax-exempt governmental bonds	Not subject to tax in the United States in a tax accounting period
United States	An entity that operates in the United States as a regulated investment company under the tax law of the United States	All passive income	Not taxed in the United States at the normal company tax rate

QC28180