• Credits on attribution from trust FIFs

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

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    Under the foreign tax credit system, the treatment of foreign taxes paid by the trustee of a foreign trust is different from that of companies.

    The beneficiary of the trust is deemed to have paid the foreign tax paid by the trustee. In general, this distinction is maintained for taxpayers with an interest in a trust FIF. [section 6AB]

    Where the calculation method is used at first tier

    As for company FIFs, if you have used the calculation method to work out attributable income of a trust FIF, a foreign tax credit is allowed for the foreign tax paid by the trustee of the trust on the income and gains of the trust FIF. The calculation is made in the same way as for a related company FIF. [section 160AFCG]

    Where the calculation method is used at second tier

    If you used the calculation method for the second tier trust FIF, a foreign tax credit is allowed for the foreign tax paid by the trustee of the trust on the income and gains of the trust FIF. The calculation is made in the same way as for a related company FIF. [section 160AFCH]

    Last modified: 27 May 2005QC 17512