Taxation Laws Amendment (Foreign Income Measures) Act 1997 (155 of 1997)
Schedule 1 Foreign source income
Part 1 General amendments
Income Tax Assessment Act 1936
56 At the end of section 457
Add:
(3) If:
(a) at the residence-change time, regulations made for the purposes of section 320 come into effect; and
(b) a result of those regulations coming into effect is that the company:
(i) ceases to be a resident of an unlisted country; and
(ii) becomes a resident of a listed country;
at the residence-change time;
then:
(c) if the company was a resident of that unlisted country throughout the period of 3 years ending at the residence-change time - no amount is to be included in the attributable taxpayer's assessable income under subsection (1) in relation to that change of residence; and
(d) in any other case - sub-subparagraph (a)(i)(A) of the definition of Adjusted distributable profits in subsection (2) does not apply in relation to that change of residence.