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BR Pub 22/01 - 22/05
Issued
29 Apr 2022
Effective
The first day of the 2022/23 income year to the last day of the 2026/27 income year.

Income tax – Australian limited partnerships and foreign tax credits

These five Rulings address the ability of a New Zealand resident partner of an Australian limited partnership to claim foreign tax credits for Australian income tax and dividend withholding tax paid by the partnership on Australian source income.  The Rulings do not consider any other situations involving foreign income and foreign tax paid.  The Rulings concern Australian limited partnerships that are corporate limited partnerships for Australian tax purposes and are treated under Australian tax law as companies while in New Zealand they retain partnership and flow through tax treatment.

A foreign tax credit will be available to the New Zealand partners of an Australian limited partnership for Australian income tax or dividend withholding tax that is paid by the limited partnership in certain situations (detailed in the Rulings).  The amount and timing of the tax credit is determined under subpart LJ of the Income Tax Act 2007.