Private ruling: Withholding tax - Managed investment trust - Foreign resident
Date of advice: 9 May 2019
Published: June 2019
Ruling period: 1 January 20XX to 31 December 20XX.
Date scheme commenced: 1 January 20XX

Ruling: Q1: Is the entity an entity of the kind specified in paragraph 275-20(4)(f) of the ITAA 1997? | A1: No.

Relevant facts and circumstances: The entity is not subject to any foreign collective investment regime. The entity is not recognised as being used for collective investment.

Relevant legislative provisions: Section 275-20 Income Tax Assessment Act 1997

Reasons for decision: Summary: The entity's business does not fall within the definition of collective investment regime in the foreign country where the entity is subject to regulation. | Detailed Reasoning - Conclusion: The entity is not an entity of the kind specified in paragraph 275-20(4)(f) as it is not recognised under a foreign law as being used for collective investment.