• Low-taxed third country income

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    The notional assessable income of a CFC in a limited-exemption listed country includes amounts derived from sources outside the CFC's country of residence if the amounts are not subject to tax in a listed country. This rule does not apply to amounts of adjusted tainted income - these amounts are included in attributable income if the CFC fails the active income test. The source of an amount is to be determined according to the laws of the CFC's country of residence.

    Last modified: 05 Dec 2006QC 17522