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What are some of the tax consequences for non-resident trusts?

If a trust is a non-resident trust, there are various tax rules (including the “transferor trust” regime, and the “foreign investment fund” regime) which may attribute some of the income of the trust to some of the Australian beneficiaries of the trust.

The purpose of these rules is to ensure that foreign sourced income of Australian residents is taxed at Australian rates of tax, and to prevent offshore accumulation of income in low or no tax jurisdictions.