• Paid to an entity other than a CFC

    Attention

    Warning:

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

    End of attention

    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