Document ID: chunk:federal_register_of_legislation:C2025C00014:section:324:p2
Version: federal_register_of_legislation:C2025C00014
Segment Type: section
Provision Reference: s 324 (pt 2/2)
Character Range: 1866871–1868216

unlisted country to a listed country), the entity was a resident of one or more listed countries (each of which is in this subsection called a  previous listed country); and
 (c) if the entity had disposed of the asset when it ceased to be a resident of a particular previous listed country (in this subsection called the non‑taxing listed country), any capital gain on the disposal would not have been subject to tax in that country; and
 (d) if the entity had disposed of the asset when it ceased to be a resident of another previous listed country after the non‑taxing listed country, any capital gain on the disposal would not have been subject to tax in that other previous listed country to the extent that it relates to the period of residence by the entity in the non‑taxing listed country;
then, for the purposes of this Part, so much of the gain as relates to the period of residence in the non‑taxing listed country is taken not to be subject to tax in the current listed country.
Note: Section 830‑75 of the Income Tax Assessment Act 1997 sets out additional circumstances, relating to entities that are foreign hybrids, in which a gain or profit is subject to tax in a listed country.
 (5) For the purposes of this section, treat foreign GloBE tax (within the meaning of the Income Tax Assessment Act 1997) as not being foreign tax.