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    <title>Foreign tax credit remains available where delayed prescribed-form filing is procedural and substantive eligibility is undisputed.</title>
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    <description>Foreign tax credit for Australian employment income cannot be denied solely because a belated return and Form No. 67 were filed late where substantive entitlement and compliance with other required formalities are undisputed. Rule 128&#039;s timing requirement is treated as a directory procedural condition in subordinate legislation and cannot curtail substantive entitlement to foreign tax credit. The credit claim was consequently required to be accepted, and the denial was set aside.</description>
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      <description>Foreign tax credit for Australian employment income cannot be denied solely because a belated return and Form No. 67 were filed late where substantive entitlement and compliance with other required formalities are undisputed. Rule 128&#039;s timing requirement is treated as a directory procedural condition in subordinate legislation and cannot curtail substantive entitlement to foreign tax credit. The credit claim was consequently required to be accepted, and the denial was set aside.</description>
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