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Foreign income return form guide 2010-11

 
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Warning: This information may not apply to the current year. Check the content carefully to ensure it is applicable to your circumstances.

FIF attribution account surpluses

Under consolidation, only the head company can operate FIF attribution accounts for the purposes of the FIF measures.

The pre-consolidation surplus balances of the FIF attribution accounts of subsidiary members of the group are transferred to the head company (or MEC group), at formation or when a subsidiary member joins the consolidated group (or MEC group). This ensures that distributions from FIFs are not taxed to the head company where the joining entity has already been subject to FIF taxation.

Once the FIF attribution account balances have been transferred to the head company of a consolidated group (or MEC group) the FIF attribution accounts of subsidiary members become inoperative during the period the entity is a member of the consolidated group (or MEC group).

When a company with an interest in a FIF leaves a group, a proportion of the head company's FIF attribution account surplus that the head company has in relation to the interests in the FIF that leaves the group with the leaving company are transferred to the leaving company.

Sections within Chapter 6: Consolidation (consolidated income tax treatment for groups of entities)

Last Modified: Wednesday, 29 June 2011
 
Table of contents
About this guide
Abbreviations and glossary
Chapter 1: Attribution of the current year profits of a controlled foreign company (CFC)
Chapter 2: Transferor trust and related measures
Chapter 3: Taxation of foreign dividends and branch profits
Chapter 4: Taxation of foreign investment fund (FIF) interests
Chapter 5: Proving your assessment
Chapter 6: Consolidation (consolidated income tax treatment for groups of entities)
More information
Appendix 1 - Foreign income regulations
Appendix 2 - Accruals taxation on the change of residence of a controlled foreign company (CFC) from an unlisted country to a listed country or to Australia
Appendix 3 - Summaries and worksheets
How self-assessment affects you
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