Further reforms to Australia’s Investment Manager Regime

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By Karen Payne

A further tranche of tax legislation to exempt ‘IMR foreign funds’ from Australian income tax has been released for public comment. Once enacted, this legislation will introduce an exemption from Australian tax for ‘widely held’ foreign funds and their investors. The tax exemption will apply to Investment Manager Regime (IMR) income as follows: a return or gain from an IMR financial arrangement that is a derivative financial arrangement; and a return or gain from a CGT event that happens in relation to an IMR financial arrangement.

An IMR financial arrangement excludes assets that represent a direct or indirect Australian real property. Annual reporting requirements apply to access the IMR regime.

The exemption for income and gains made in these circumstances is intended to remove impediments to foreign investment into or through Australia by foreign managed funds…

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