• Exemption for small amounts

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

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    An exemption applies for CFCs in broad-exemption listed countries if the total of:

    • eligible designated concession income low-taxed foreign source income and
    • FIF income

    is not greater than a threshold amount. There is no similar exemption for a CFC that is a resident of a non-broad-exemption listed country.

    Threshold amount

    If the CFC has a gross turnover of $1 million or more, the threshold amount is $50,000 - that is, the exemption will only apply if the total of the amounts is $50,000 or less.

    If a CFC has a gross turnover of less than $1 million, the threshold amount is 5% of the CFC's gross turnover - that is, the exemption will only apply if the sum of the amounts is less than or equal to 5%.

    How does the exemption operate?

    If the threshold is not exceeded, a CFC's eligible designated concession income, low-taxed foreign source income and FIF income are not included in the notional assessable income of the CFC. The general anti-avoidance provisions of the Act may apply where attempts are made to split income among a number of CFCs to take advantage of the exemption.

    Last modified: 05 Dec 2006QC 17522