Section 2 - Are you an attributable taxpayer?



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End of attention

If you have an interest in a CFC you must determine if you are an attributable taxpayer. You are only required to include an amount of attributable income from a CFC in your assessable income if you are an attributable taxpayer in relation to the CFC.

You will be an attributable taxpayer if:

  • you have an associate-inclusive control interest of 10% or more in a CFC, or
  • all of the following rules apply:
    • the CFC is a CFC because of the application of the de facto control test
    • you are an Australian 1 per cent entity
    • you are part of a group of five or fewer Australian entities who, alone or with associates - regardless of whether the associates are Australian entities - control the CFC.
Last modified: 05 Dec 2006QC 18000