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Classification of Korean Hapja Hoesa for Australian income tax purposes — Orbitax Tax News & Alerts

The Australian Taxation Office released Interpretative Decision ID 2006/91 clarifying that a South Korean Hapja Hoesa (i.e. South Korean limited joint company established under the Indirect Investment Asset Management Act 2003) is a corporate limited partnership.

Corporate limited partnerships are treated as companies for Australian income tax purposes.

Further, ID 2006/91 states that a Hapja Hoesa does not qualify as a foreign hybrid limited partnership under the Australian foreign hybrid rules in Division 830 of the Income Tax Assessment Act 1997.