Commentary

D6.502A International movement of capital—excluded transactions

Corporate tax
Corporate tax | Commentary

D6.502A International movement of capital—excluded transactions

Corporate tax | Commentary

D6.502A International movement of capital—excluded transactions

A transaction is specifically excluded from the international movement of capital provisions (see D6.502) if1:

  1.  

    (a)     it is carried out in the ordinary course of a trade

  2.  

    (b)     all the parties to the transaction are resident in the same territory (at the time the transaction takes place)

  3.  

    (c)     the transaction consists of the giving of security:

    1.  

      (1)     to the bankers of a foreign subsidiary for any payment due from the subsidiary to the bankers by reason of any transaction entered into in the ordinary course of the bankers business, or

    2.  

      (2)     by a foreign

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