Tax & Superannuation: International - Guides
International
5. International Trusts
Firm / Chambers:
Last updated: 31 Jul 2015
- An Australian resident company may become subject to Australian taxation if it has:
- transferred property or services to a non-resident discretionary trust; or
- transferred property or services to a non-resident, non-discretionary trust for inadequate or no consideration.
- These measures are broadly aimed at trusts in low tax jurisdictions that accumulate income without paying Australian tax. The income to be attributed to resident beneficiaries will be based on a percentage that is equal to the percentage of the beneficiary’s interest in and entitlement to acquire income of the trust.
- The relevant provisions are very complex and it is recommended that professional advice be sought.
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