If the partnership received assessable dividends directly or indirectly from a New Zealand franking company, the dividends (including any supplementary dividends) must be declared as assessable foreign income even if dividend withholding tax was deducted in New Zealand. The individual partners may be able to claim a foreign income tax offset for any New Zealand dividend withholding tax paid on the dividend. See the Foreign income return form guide to work out whether the dividend is assessable income.
If the dividend from a New Zealand company is assessable income, then the amount of the Australian franking credit attached to the dividend is also assessable income if the partnership is eligible to receive imputation benefits. Subject to the holding period rule and related payments rule, the partnership can claim a franking tax offset equal to the amount of the Australian franking credit included in its assessable income. For more information, see appendix 1.
The dividend may include an amount of New Zealand imputation credits. Australian residents cannot claim any amounts of New Zealand imputation credits.
All dividend income, deductions and foreign tax paid must be converted into Australian dollars. The amount of Australian franking credits should already be expressed in Australian dollars.
End of attentionChanges to income tests require each partner to report their share of the partnership rental property income or loss. As such, if you have included foreign rental income at item 23, complete your share of net rental property income or loss at K item 65. See Income tests.
End of attentionGross foreign source income
Show at B the gross amount of assessable income derived from foreign sources, including amounts distributed from other partnerships and trusts as well as New Zealand dividends and supplementary dividends. Include any foreign tax paid on that income.
Do not include at B:
- any income which is exempt from tax in Australia or treated as non-assessable non-exempt income under sections 23AI and 23AK of the ITAA 1936
- any amount of New Zealand imputation credits
- any amount of Australian franking credits attached to dividends from a New Zealand franking company; show these at D
- income already shown at item 22 Attributed foreign income
- any foreign source capital gains or capital losses.
Each partner must include their share of any foreign source capital gains or capital losses on their own tax return.
In referring to 'foreign source capital gains' an Australian resident partner makes a capital gain if a CGT event happens to any of their worldwide CGT assets.
A partner that is not an Australian resident makes a capital gain, generally speaking, only if their CGT asset is taxable Australian property just before the CGT event happens.
If what you show at B includes an amount which is brought to account under the TOFA rules, also complete item 31 Taxation of financial arrangements (TOFA). This may include TOFA gains from unrealised movements in the value of financial arrangements.
End of attentionNet foreign source income
Show at V the net income derived from foreign sources.
The amount at V is the gross amount shown at B, less any deductions allowable to the partnership against that income. Debt deductions (such as interest and borrowing costs) that relate to assessable foreign source income and that are not attributable to an overseas permanent establishment of the taxpayer are not applied against assessable foreign source income for the purpose of calculating net foreign income or identifying a foreign loss. Do not claim these amounts here. Include them at item 18 Other deductions.
If the amount at V is negative, print L in the box at the right of the amount.
If what you show at V includes an amount which is brought to account under the TOFA rules, also complete item 31Taxation of financial arrangements (TOFA).
End of attentionCurrent year foreign losses
From a partnership's first income year starting on or after 1 July 2008 (the commencement time), foreign losses are no longer quarantined from domestic assessable income (or from assessable foreign income of a different class). Resident taxpayers are also no longer required to make an election to deduct domestic tax losses against assessable foreign income. Newly introduced, section 770-1(4) of the Income Tax (Transitional Provisions) Act 1997 ensures that relevant foreign losses converted into tax losses can be deducted in calculating the partnership's net income or loss under section 90 of the ITAA 1936, and so be distributed to the partners for use against their own assessable income. (See Subdivisions 770-A - Transitional foreign losses (common rules) and 770-B - Transitional foreign losses (special rules for consolidated groups) of the Income Tax (Transitional Provisions) Act 1997).
For more information on the transitional rules, see Changes to foreign loss quarantining and foreign tax credit calculation rules - Overview, Foreign income return form guide and Guide to foreign income tax offset rules.
End of further informationForeign income tax offsets
Show at Z the amount of any foreign income tax paid by the partnership on foreign source income.
If foreign income tax has actually been paid by the partnership then the partners may be able to claim a foreign income tax offset in their individual income tax returns.
Example 10
A partnership of two Australian partners with equal interests in all income of the partnership derives net income of $1,000 on which it pays $100 of foreign income tax. The partners each include $500 in their assessable income, being their share of the net income of the partnership. They will both be entitled to a tax offset to the extent that foreign income tax is paid on the amount that is part of their assessable income. The foreign income tax paid is apportioned according to each partner's share of the net income of the partnership included in their assessable income. Therefore, each claims an offset for $50 of foreign income tax, as this is the proportionate amount of foreign income tax they are taken to have paid on the amount included in their assessable income (that is, (500/1,000) $100).
For more information see the publications Changes to foreign loss quarantining and foreign tax credit calculation rules - Overview, Foreign income return form guide and Guide to foreign income tax offset rules.
Australian franking credits from a New Zealand company
Show at D the amount of Australian franking credits that are included in the net income of the partnership because of franked dividends received from a New Zealand franking company directly or indirectly through another partnership.
The amount shown at D is not necessarily the total amount that each partner can claim. See appendix 1.