Commonwealth Numbered Regulations

1991 No. 20 INCOME TAX REGULATIONS (AMENDMENT) - SCHEDULE 9

                       SCHEDULE 9                Paragraph 152D (1) (c)

PART 1
INTERPRETATION 1. In this Schedule, unless the contrary intention appears,
words and phrases have the same meanings as they have in Part X of the Act or
Part 8A of these Regulations, as the case requires. 2. In this Schedule, a
reference to a law of a listed country is a reference to that law as amended
and in force from time to time.
PART 2
ENTITIES AND LISTED COUNTRIES REFERRED
TO IN PARAGRAPH 152D (1) (c)
Column 1  Column 2         Column 3

Item No.  Listed country   Entity

1         Belgium          An entity that is recognised or qualified as

a co-ordination centre under a law of Belgium
2         Belgium          An entity that is recognised or qualified as

a Foreign Sales Corporation under a tax law of the
United States of America
3         Belgium          An entity that is recognised or qualifies as

a distribution centre under a law of Belgium
4         Brazil           An entity that is recognised or qualifies as, or

derives income or profits through, an authorised
investment fund formed under Decree-law No.
1.401 of Brazil
5         Bulgaria         An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) from activities or operations
carried on in one or more of the following zones
of Bulgaria:

   (a)  the Burgas Duty Free Zone;

   (b)  the Plovdiv Duty Free Zone;

   (c)  the Rousse Duty Free Zone;

   (d)  the Svilengrad Duty Free Zone;

   (e)  the Vidin Duty Free Zone
6         France           An entity that operates in France as a

headquarters entity under a law of France or by
virtue of an administrative arrangement with the
French authorities
7         Germany,         An entity that operates in the Federal Republic of

          Federal          Germany as a headquarters entity in accordance
with
          Republic of      the Decree on management centres

(Kontrollstellenerlass) of 24 August 1984
8         Greece           An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Greece in the tax accounting period referred to
in that paragraph because of Law 89/1967 of
Greece
9         Hungary          An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Hungary in the tax accounting period referred to
in that paragraph because of Decree No. 1 of
1977 of the Ministry for Finance of Hungary
10        Ireland          An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) from goods manufactured in Ireland
11        Ireland          An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) from activities undertaken in the
Shannon Airport Zone
12        Ireland          An entity that drives income or profits during

the relevant period referred to in paragraph
152D (1) (c) from design and planning services
carried out in Ireland in connection with
chemical, civil, electrical or mechanical
engineering projects executed outside the
European Community
13        Ireland          An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) from computer services, including
data processing and software development
services, and technical and related consultancy
services
14        Ireland          An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) from the provision of international
financial services, undertaken within the Dublin
Custom House Docks area, to persons not
ordinarily resident in Ireland
15        Ireland          An entity that derives income or profits during
the
the relevant period referred to in paragraph
152D (1) (c) from shipping activities in
relation to the carriage of passengers or cargo
in ships that are owned and registered in
Ireland, the provision of ancillary services on
board those ships or the chartering of those
ships
16        Ireland          An entity that operates in Ireland as a

headquarters entity under a law of Ireland or by
virtue of an administrative arrangement with the
Irish authorities
17        Israel           An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Israel in the tax accounting period referred to
in that paragraph because of the Law for the
Encouragement of Capital Investment (1959) of
Israel
18        Luxembourg       An entity that is recognised or qualifies as a

Holding company under a law of Luxembourg
19        Luxembourg       An entity that carries on any reinsurance business

in Luxembourg
20        Luxembourg       An entity that is recognised or qualifies as a

co-ordination centre under a law of Luxembourg
21        Malaysia         An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Malaysia in the tax accounting period referred
to in that paragraph because of section 60, 60A
or 60B of the Income Tax Act 1967 of Malaysia
22        Malaysia         An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Malaysia in the tax accounting period referred
to in that paragraph because of section 60E of
the Income Tax Act 1967 of Malaysia
23        Malta            An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Malta in the tax accounting period referred to
in that paragraph because of the International
Business Activities Act 1988 of Malta or the
Offshore Trusts Act 1988 of Malta
24        Netherlands      An entity that operates in the Netherlands as a

headquarters entity under a law of the
Netherlands or by virtue of an administrative
arrangement with the Netherlands authorities
25        Netherlands      An entity that is recognised or qualifies as a

Foreign Sales Corporation under a tax law of the
United States of America
26        Pakistan         An entity that is engaged in air transport
operations of any kind (including the leasing of aircraft)
27        Philippines      An entity that is an Offshore Banking Unit or a

Foreign Currency Deposit Unit within the meaning of
Presidential Decree 1034 or 1035 of 30
September 1976 of the Philippines or regulations
under any of those Decrees
28        Philippines      An entity that operates in the Philippines as an

area or regional headquarters entity under a law
of the Philippines or by virtue of an
administrative arrangement with the Philippines
authorities
29        Portugal         An entity that is approved under, and whose

activities or operations are regulated by:

   (a)  Decree-Law 500/80 of 20 October 1980; or

   (b)  Regulatory Decree 53/82 of 23 August 1982;
or

   (c)  Decree-Law 163/86 of 26 June 1986 as amended
by Decree-Law 197/88 of 31 May 1988 and
Decree-Law 15/89 of 1 February 1989; or

   (d)  Decree-Law 352-A/88 of 3 October 1988; or

   (e)  Decree-Law 502/85 of 30 December 1985 as
revised by Decree-Law 165/86 of 26 June 1986
30        Portugal         An entity that is approved under, and whose

activities are regulated by:

   (a)  Decree-Law 34/82 of 4 February 1982; or

   (b)  Regulatory Decree 54/82 of 23 August 1982; or

   (c)  Decree-Law 501/85 of 28 December 1985; or

   (d)  Regional Legislative Decree 21/86A of 27
October 1986 or;

   (e)  Decree-Law 63/87 of 5 February 1987; or

   (f)  Regional Legislative Decree 19/87A of 28
November 1987
31        Singapore        An entity that derives income or profits during
the
relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Singapore in the tax accounting period referred
to in that paragraph because of the Income Tax
(Concessionary Rate of Tax for Asian Currency
Unit Income) Regulations 1988
32        Singapore        An entity that derives income or profits during
the
relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Singapore in the tax accounting period referred
to in that paragraph because of the Income Tax
(Concessionary Rate of Tax for Approved
Securities Companies) Regulations 1988
33        Singapore        An entity that derives income or profits during
the
relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Singapore in the tax accounting period referred
to in that paragraph because of the Income Tax
(Income from Syndicated Offshore Credit and
Underwriting Facilities) Regulations 1986
34        Singapore        An entity that derives income or profits during
the
relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Singapore in the tax accounting period referred
to in that paragraph because of the Income Tax
(Concessionary Rate of Tax for Approved Fund
Managers) Regulations 1988
35        Singapore        An entity that derives income or profits during
the
relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Singapore in the tax accounting period referred
to in that paragraph because of the Income Tax
(Concessionary Rate of Tax for Income from
Insuring and Reinsuring Offshore Risks)
Regulations 1980
36        Singapore        An entity that derives income or profits during
the
relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Singapore in the tax accounting period referred
to in that paragraph because of the Income Tax
(Concessionary Rate of Tax for Income from Gold
Bullion, Gold Futures and Financial Futures)
Regulations 1985
37        Singapore        An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Singapore in the tax accounting period referred
to in that paragraph because of the Income Tax
(Concessionary Rate of Tax for Approved
Headquarters Company) Regulations 1988
38        Singapore        An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Singapore in the tax accounting period referred
to in that paragraph because of the Income Tax
(Income from Funds Managed for Foreign
Investors) Regulations 1988
39        Singapore        An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Singapore in the tax accounting period referred
to in that paragraph because of regulations made
under section 43F of the Income Tax Act of
Singapore
40        Singapore        An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c), of a kind attributable to the
provision of financial services (including
insurance) within the meaning of paragraph

(3) (c) of Article 18 of the Singapore agreement
within the meaning of the Income Tax
(International Agreements) Act 1953, if the
income or profits are subject to a reduction of
tax under a tax law of Singapore in the tax
accounting period referred to in that paragraph
because of the Economic Expansion Incentives
(Relief from Income Tax) Act 1988 of Singapore
41        Solomon          An entity that carries on insurance business

          Islands          of any kind in the Solomon Islands

42        Solomon          An entity that is engaged in air transport

          Islands          operations of any kind (including the leasing

of aircraft)
43        Spain            An entity that operates in Spain as a headquarters

entity and the entity is authorised
by the Minister of Economy and Finance of Spain
to hold shares in foreign entities but is not
authorised to carry on business in Spain
44        Spain            An entity that is registered with the Minister

of Economy and Finance of Spain as a venture
capital company or fund under Royal Decree-Law 1
of 14 March 1986 of Spain
45        Sri Lanka        An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Sri Lanka in the tax accounting period referred
to in that paragraph because of sections
8 (c) (iv) and 15 (cc) of the Inland Revenue Act
of Sri Lanka
46        Switzerland      An entity that is recognised or qualifies as

a holding company under a law of a Swiss canton
or Switzerland
47        Switzerland      An entity that is recognised or qualifies as a

service or auxiliary company under a law of a
Swiss canton or Switzerland
48        Switzerland      An entity that is recognised or qualifies as a

domiciliary company under a law of a Swiss
canton or Switzerland
49        Switzerland      An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Switzerland in the tax accounting period
referred to in that paragraph because of Article
59 of the Decree of the Federal Council on
levying a Federal Direct Tax
50        Tonga            An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Tonga in the tax accounting period referred to
in that paragraph because of the provisions of
the Tonga Off-Shore Banking Act 1984
51        Turkey           An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Turkey in the tax accounting period referred to
in that paragraph because of Articles 8 (4),
8 (6), 8 (7), 8 (8) or 8 (10) of Law 5422 of 3
June 1949 of Turkey
52        Western Samoa    An entity that derives income or profits during

the relevant period referred to in paragraph
152D (1) (c) if the income or profits are
subject to a reduction of tax under a tax law of
Western Samoa in the tax accounting period
referred to in that paragraph because of the
provisions of the International Insurance Act
1988, the International Trusts Act 1987 or the
Offshore Banking Act 1987 of Western Samoa