Private ruling: Application of the rules in Part X and Division 770 of the ITAA 1936
Date of advice: 21 March 2017
Published: August 2017

Ruling: Q1: Will Entity A be a resident of a listed country pursuant to section 332 of the ITAA 1936? | A1: No. | Q2: If the answer to Question 1 is negative, will Entity A be a resident of an unlisted country in accordance with section 333 of the ITAA 1936? | A2: Yes. | Q3: If the answer to Question 2 is affirmative, does section 403 of the ITAA 1936 apply to any income, profit or gains derived or made by Entity A from its investment in Entity B to the extent it is not eligible designated concession income? | A3: Yes. | Q4: Will the beneficiaries of Trust C be entitled to claim a foreign income tax offset pursuant to section 770-10 of the ITAA 1997 in respect of distributions sourced from Entity A to the extent that those distributions are included in the beneficiaries' assessable income? | A4: Yes.




Subject: Application of the rules in Part X and Division 770 of the ITAA 1936: In order to protect the privacy and commercial-in-confidence components of this private ruling the following summary is provided.