(1) The rates of tax payable by a trustee of a complying ADF in respect of the taxable income of the fund are:
(a) in respect of the low tax component--15%; and
(b) in respect of the non - arm's length component--45%.
(2) The rate of tax payable by a trustee of a non - complying ADF in respect of the taxable income of the fund is 45%.