Attachment B

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

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

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

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

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

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

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

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

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

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

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

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

Either:

(a) a company that is treated as a resident of the United States of America for the purposes of the tax law of the United States, or

(b) any entity in carrying on business in the United States of America 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 of America in a tax accounting period

An entity that operates in the United States of America as a regulated investment company under the tax law of the United States of America

All passive income

Not taxed in the United States of America at the normal company tax rate