Table of Contents
Preface
Table of Contents
Chapter 1 - Introduction
1.1 Purpose of the Consultative Document
1.2 Reasons for the Measures
1.3 Consultative Committee
1.4 Terms of Reference
1.5 Submissions
1.6 Outline of the Document
1.7 Meaning of Terms Used
Chapter 2 - Summary
2.1 Income Subject to the Measures
2.2 Branch-Equivalent Basis
2.3 Comparative-Value Basis
2.4 Distributions from Non-Resident Companies and Trusts
2.5 Effective Dates
2.6 Disclosure and Administration
Chapter 3 - Objectives of the Reform Measures
3.1 Introduction
3.2 The Issues at a Glance
3.3 Deficiencies in Existing Law
3.4 Objectives of Reform
3.5 Context of Reform
3.6 Impact of the Measures
3.7 Conclusion
Chapter 4 – Income Subject to the Reform Proposals
4.1 Scope of Reform
4.2 Non-Resident Companies
4.3 Non-Resident Trusts
4.4 Bases for Reporting Income
Chapter 5 - Reporting Income on a Branch-Equivalent Basis
5.1 Overview
5.2 Non-Resident Companies
5.3 Non-Resident Trusts
5.4 Election to Report Income on Branch-Equivalent Basis
5.5 Changing from Branch-Equivalent to Comparative-Value Basis
Appendix 5.1 Schematic Outline of Income Attribution Rules
Appendix 5.2 Example of Attribution Rules in Operation
Chapter 6 - Reporting Income on a Comparative-Value Basis
6.1 Non-Resident Companies
6.2 Non-Resident Trusts
6.3 Beneficial Interests in Discretionary Non-Resident Trusts
6.4 Changing from Comparative-Value to Branch-Equivalent Basis
Chapter 7 - The Taxation of Distributions
7.1 Introduction
7.2 Foreign Dividends
7.3 Assessable Distributions from Trusts
7.4 Relief for Branch-Equivalent Taxes
7.5 Foreign Tax Credits
7.6 Disguised Distributions
Chapter 8 - Disclosure and Administration
8.1 Introduction
8.2 Disclosure
8.3 Administration