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 Austr…