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  • Paid to an entity other than a CFC



    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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    Similar rules apply where an unlisted country CFC pays a dividend to:

    • a controlled foreign trust (CFT)
    • a partnership of which a CFC or a CFT is a partner
    • an Australian trust of which a CFC or a CFT is a beneficiary or
    • a partnership or Australian trust from which a CFC (or a CFT) benefits through interests in interposed entities.

    The rules apply if:

    • the dividend paid by the unlisted country CFC would have been a non-portfolio dividend if it had been paid to a company instead of the partnership or trust and
    • the resident taxpayer was an attributable taxpayer for both the CFC that paid the dividend, and the CFC or CFT that received the dividend.
    Last modified: 05 Dec 2006QC 17522