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  • Section 2: What if a CFC receives a dividend from another CFC?



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    Non-portfolio dividends paid by a foreign company to a CFC are non-assessable non-exempt income of the CFC. Therefore, such dividends cannot form part of the attributable income of the CFC in relation to which an attributable taxpayer may be assessable under section 456.

    Last modified: 18 May 2020QC 19443