Private ruling: Superannuation fund for foreign residents and withholding tax
Date of advice: 16 August 2019
Published: January 2020

Ruling: Q1: Is Entity A, as manager of the Pension Plan Fund (the Fund), exempt from liability to withholding tax on interest, dividend and non-share dividend income derived from its direct investments into Australia under paragraph 128B(3)(jb) of the Income Tax Assessment Act 1936 (ITAA 1936)? | A1: Yes