Commentary

D4.804 Rules applicable only to companies

Corporate tax
Corporate tax | Commentary

D4.804 Rules applicable only to companies

Corporate tax | Commentary

D4.804 Rules applicable only to companies

The provisions in this article apply only to companies where an election has not been made for exemption for the profits of a foreign permanent establishment (D4.801). For details of the double tax relief provisions that generally apply equally to companies and individuals see Division E6.4.

In addition to the general rules that apply equally to companies and individuals (see Division E6.4), there are a number of specific provisions that apply only to companies in relation to:

  1.  

    (a)     the definition of a subsidiary. For double taxation relief purposes a company is a subsidiary of another

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