Australia: Information about deemed payments from Attribution Managed Investment Trusts (AMIT)

12.07.2017

Clearstream Banking1 would like to inform customers that for deemed payments made after

1 July 2017

the new taxation regime for Managed Investment Trusts (MITs) will apply, if the MIT has opted-in to the regime.

Background

The Australian Government has passed Bills detailing a new taxation regime for Managed Investment Trusts (MITs).

The new regime for Attribution Managed Investment Trusts (AMIT) has a start date for income years on or after 1 July 2016 and a number of MITs have now opted-in to the regime.

The Bill introduces the concept of deemed payments whereby taxable income is deemed to have been derived by a unitholder and non-resident withholding tax applied even where no actual distribution of cash takes place.

Impact on customers

Distributions from AMITs will be treated as follows:

  • Interim distributions for AMITs are announced and taxed in the same way as currently applies to MITs (Unit Trusts);
  • After the end of each income year (30 June each year) an AMIT will release an AMIT Member Annual Statement (AMMA Statement) which will detail the tax components of the distribution attributed (or allocated) to unit holders for the year. Depending on the AMIT’s cash distribution policy, customers may be taxed on deemed payments where no cash was received;
  • Our depository, J.P. Morgan, will allocate deemed payments to unit holders at the final record date of the income year whereby non-resident withholding tax may be debited from customer accounts irrespective of whether our customers received a cash distribution;
  • Withholding tax will be consequently debited from customer accounts according to the tax certification provided by customers (when applicable, according to the new distribution’s components).

Further information

The Market Taxation Guide – Australia will be updated in due course.

For further information, please contact the Clearstream Banking Tax Help Desk, Clearstream Banking Client Services or your Relationship Officer.

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1. Clearstream Banking refers collectively to Clearstream Banking S.A., registered office at 42, avenue John F. Kennedy, L-1855 Luxembourg, and registered with the Luxembourg Trade and Companies Register under number B-9248, and Clearstream Banking AG (for Clearstream Banking Frankfurt (CBF) customers using CreationOnline), registered office at 61, Mergenthalerallee, 65760 Eschborn, Germany and registered in Register B of the Amtsgericht Frankfurt am Main, Germany under number HRB 7500.