Attribution of non-resident trust income under the FIF measures



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

End of attention

Prior to the FIF measures the assessable income of an Australian beneficiary who was not under a legal disability included the share of the net income of a non-resident trust estate to which the beneficiary was presently entitled and which was attributed to a period when the beneficiary was a resident of Australia. [SECTION 97]

Since the FIF measures your share of the income of a FIF which is a foreign trust is worked out in the same manner as other FIFs, either by the:

  • market value method
  • deemed rate of return method, or
  • calculation method.

Since the commencement of the FIF measures, where an amount is worked out in accordance with one of the above methods and included in the assessable income of the beneficiary as FIF income or loss, no amounts are included in the assessable income of an Australian beneficiary under the general trust provisions. [SECTIONS 96A, 97 and 529]

Last modified: 08 Jun 2005QC 27386