|
此文章由 jeff_lawsons 原创或转贴,不代表本站立场和观点,版权归 oursteps.com.au 和作者 jeff_lawsons 所有!转贴必须注明作者、出处和本声明,并保持内容完整
It should be possible for the discretionary trust to distribute income to a non-resident as long as the non-resident is a potential beneficiary of the trust. You need to check the trusts' deed.
If the trust has distributed its income to non-resident beneficiaries then the treatment would generally be as follows:
• Distributions to a non-resident beneficiary that relate to Australian sourced interest, royalties or unfranked dividends should be subject to non-resident withholding tax at the appropriate rates (depending on the country involved).
• Distributions to a non-resident that relate to foreign sourced income should not be subject to any Australian tax.
• Distributions to a non-resident that relate to franked dividends should not be subject to any further Australian tax.
• Distributions of other Australian sourced income will be taxed in the hands of the trustee of the trust on behalf of the non-resident beneficiaries. The non-resident beneficiary would also normally be assessed although they would receive a credit for tax paid by the trustee. If the beneficiary is an individual then non-resident individual tax rates will apply.
|
评分
-
查看全部评分
|