Taxation (International and Other Provisions) Act 2010 section 363

Meaning of "umbrella arrangements" and "part of umbrella arrangements"

Section 363 defines the terms "umbrella arrangements" and "part of umbrella arrangements" as used throughout this Part of the Act.

• Umbrella arrangements are arrangements where participants' contributions, profits, and income are kept in separate pools rather than being mixed together.
• Each separate pool within an umbrella arrangement is treated as a distinct "part" of those umbrella arrangements.
• Payments to participants are made out of the profits or income allocated to their respective separate pool.
• These definitions apply consistently wherever the terms are used throughout this Part of the legislation.