TaxCounsel Imagery

ATO Rulings and Determinations

Foreign hybrid limited partnership
21.01.2009

A final determination (TD 2009/2) considers when foreign income tax is imposed on the partners, not the partnership, within the meaning of sec 830-10(1)(b) ITAA 1997 for the purpose of determining whether a foreign limited partnership is a foreign hybrid limited partnership under Div 830 ITAA 1997 (foreign hybrids).

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