What does conduit foreign income mean for different types of entities?
Resident individuals The conduit foreign income (CFI) rules do not affect the tax position of a resident individual. A resident individual who receives a distribution wholly or partly of unfranked amounts declared to be CFI would include the distribution in their assessable income as an unfranked distribution. Non-residents The CFI rules provide non-resident individuals with an exemption from withholding tax on an unfranked distribution received from an Australian corporate tax entity (CTE) to the extent that that distribution is declared to be CFI on the distribution statement. The amount is also non-assessable, non-exempt income of the non-resident. An Australian corporate tax entity The CFI measures mean that an Australian CTE can: • declare all or part of an unfranked distribution to be CFI in a distribution statement. Where that distribution is made to a foreign resident, the CTE will not be obliged to withhold an amount to the extent it is declared to be CFI, and • treat a portio
