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TD 2017/22 - Income tax: where an Australian corporate tax entity is a beneficiary of a trust, can the trust 'hold' a direct control interest (within the meaning of section 350 of the Income Tax Assessment Act 1936) in a foreign Co for the purpose of Subdivision 768-A of the Income Tax Assessment Act 1997 ?   flag 

[2017] ATOTD 22
Australian Taxation Office
Australia - Commonwealth

Legislation Cited

Legislation Name Provision
Income Tax Assessment Act 1936 (Cth) s350
Income Tax Assessment Act 1997 (Cth) s35.1
Taxation Administration Act 1953 (Cth) s15

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