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The FIF rules apply in working out the attributable income of a CFC because of the assumption that the company is a resident of Australia. However, rules apply to prevent double taxation where a company FIF is also a CFC. These rules provide an exemption from the FIF measures for an interest held by a CFC in a company FIF if a share of the attributable income of the company FIF is included in your assessable income under the CFC measures for:
- a statutory accounting period coinciding with the notional accounting period of the company FIF for FIF taxation purposes or
- statutory accounting periods ending and commencing during the notional accounting period of the company FIF.
For the purposes of the above tests, the Tax Office will accept that a share of the attributable income of a company FIF has been included in your assessable income if no amount was included solely because the company FIF had no attributable income. Refer to Taxation Determination TD 93/ 167 for further assistance.
Last modified: 05 Dec 2006QC 17522