Collective investment schemes: unauthorised unit trusts: taxation of the investor: foreign double tax relief
Cases involving double tax relief
Where there is a ‘foreign element’ included in a deemed payment to a unit holder, ITA07/S848 does not apply to the foreign element of the deemed deduction treated as made from any deemed payments (ITA07/S943B).
Any unit holders affected by this rule should receive an ‘annual statement’ informing them of -
- the date on which the deemed payment was treated as made,
- the gross amount of the deemed payment,
- the foreign element (if any) of the deemed income represented by the deemed payment,
- the deemed deduction made from the deemed payment, and
- the foreign element (if any) of that deemed deduction.