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End of attention
If a CFC passes the active income test, amounts that would be assessable if the CFC were a resident are included in attributable income to the extent they represent the following:
- low-taxed third country income
- trust amounts arising to the CFC directly that are not subject to tax in a broad-exemption listed country
- trust amounts arising to the CFC indirectly because the CFC is a partner in a partnership, provided that the amounts are not subject to tax in a broad-exemption listed country
- FIF income derived by the CFC directly or indirectly as a partner in a partnership.
Any other income is notional exempt income.
Diagram of amounts taken into account
Last modified: 05 Dec 2006QC 17522