Dividends deemed paid by a CFC to a CFC or CFT



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If a non-portfolio dividend is deemed, under section 47A, to have been paid by an unlisted country CFC to:

  • a listed country CFC, or
  • a controlled foreign trust (CFT), or
  • a CFC or CFT through interposed partnerships or Australian trusts

and a resident taxpayer holds an attribution interest in the CFC deemed to have paid the dividend and in the other CFC or CFT, the taxpayer's attribution percentage of the deemed dividend will be included in its assessable income - see section 458. However, this attribution will not occur if the dividend is taxed in a listed country at its normal company tax rate.

Last modified: 05 Dec 2006QC 17522