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  • Section 2: What is the purpose of the active income test?



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    The active income test is used to determine whether a CFC is predominantly engaged in carrying on an active business. An exemption from accruals taxation is available for certain amounts if the test is satisfied.

    To determine whether the CFC is mainly engaged in carrying on an active business, the first step is to determine amounts that are likely to be earned in a low-tax jurisdiction to defer Australian tax. These amounts are compared to the CFC's total income to determine the proportion of potential tax deferral activities. Only if this proportion is less than 5% will the CFC be taken to be mainly engaged in genuine business activities.

    The meaning of special terms used in the following commentary are contained in section 1 of this part.

    Last modified: 18 May 2020QC 19443