A distribution that an Australian corporate tax entity makes to a foreign resident is not subject to dividend withholding tax, and is not assessable income, to the extent that the entity declares it to be conduit foreign income.
An Australian corporate tax entity has an amount that is non - assessable non - exempt income if it receives a distribution including conduit foreign income from another such entity and it makes a distribution including conduit foreign income.
This Subdivision sets out the method of working out an entity's conduit foreign income.
It also discourages streaming of distributions to entities that can take advantage of the receipt of conduit foreign income.
Table of sections
Operative provisions
802 - 10 Objects
802 - 15 Foreign residents--exempting CFI from Australian tax
802 - 17 Trust estates and foreign resident beneficiaries--exempting CFI from Australian tax
802 - 20 Distributions between Australian corporate tax entities--non - assessable non - exempt income
802 - 25 Conduit foreign income of an Australian corporate tax entity
802 - 30 Foreign source income amounts
802 - 35 Capital gains and losses
802 - 40 Effect of foreign income tax offset on conduit foreign income
802 - 45 Previous declarations of conduit foreign income
802 - 50 Receipt of an unfranked distribution from another Australian corporate tax entity
802 - 55 No double benefits
802 - 60 No streaming of distributions