Guide to completing Schedule 25A

Attribution percent x interest/entitlement x section 456 to 459A amount

The attribution percentage is the sum of the direct and indirect interests that you, an attributable taxpayer, hold in the controlled foreign company. The interests of associates are not included.

Example of attribution percentage

• Attribution percentage means the attributable taxpayer's attribution percentage for the controlled foreign company or controlled foreign trust
• Interest/entitlement means the percentage of the net income of the Australian partnership or the Australian trust represented by the sum of the direct and indirect interests or present entitlements of the controlled foreign company or controlled foreign trust
• Section 456 to 459A amount means amounts calculated under those sections.

Example:

• AustCo owns 100% of CFC1
• CFC1 is a partner of AustPa and has a 50% right to the partnership's income and capital
• AustPa owns 100% of CFC2
• $200 Attributable income from CFC2 is included in income of AustPa

Formula:

AP	x	Interest/entitlement			x	Section 456 to 459A amount
Aust Co		100%	x	50%		$200

Aust Co would be assessable on $100

Refer to Division 9 of Part X of the ITAA 1936 for more information.

Sections within Definition glossary

• Permanent establishment or branch
• International related parties
• Central management and control
• Participates in capital
• Relationship
• Transactions
• Related-party international dealings
• Tangible property
• Intangible property
• Services
• Other transactions
• Aggregate amount
• Total dollar value
• Non-monetary consideration
• Arm's length principle
• Transfer pricing
• Arm's length pricing methods
• Arm's length pricing codes and methodology
• Documentation
• Pricing methods for capital assets
• Listed and unlisted countries
• Controlled foreign company
• Controlled foreign entity
• Controlled foreign partnership
• Controlled foreign trust
• Eligible transferor
• Attributable taxpayer
• Attributable income
• Tainted income
• Active income test
• Eligible designated concession income
• Tainted assets
• Non-portfolio dividends
• Foreign investment fund
• Foreign life insurance policy
• Attribution account
• Subdivision 768-G of ITAA 1997
• Underlying active business
• Extent of the reduction
• Foreign company assets
• Non-resident trust estate
• Entitled to acquire
• Attribution percent x adjusted distributable profits
• Attribution percent x interest/entitlement x section 456 to 459A amount
• Discretionary trust estate
• Control in relation to a trust estate
• Notional accounting period
• Interests in a foreign investment fund or foreign life policy
• What income has been comparably taxed?
• Non-assessable non-exempt income
• Controlled foreign company rules
• Foreign investment fund rules
• Transferor trust rules
• Foreign company
• Foreign trust
• Change of residence of a controlled foreign company from an unlisted country to Australia
• Change of residence of a controlled foreign company from an unlisted country to a listed country