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End of attention
Your assessable income must include your attribution percentage of a FIF's calculated profit.
Attribution percentage for interests in a foreign company - boxes E and G
The attribution percentage for your FIF interest is equal to the percentage that you hold or were entitled to acquire at the end of the notional accounting period in:
- the total paid-up share capital of the company
- the total rights to vote or to participate in decision making in relation to
- distributions of profit or capital of the company
- the constituent document of the company
- a variation to the share capital of the company, or
- the total rights to distributions of profit or capital on winding-up, or at any other time.
The FIF attribution percentage will be the greatest of the percentages if different percentages arise under the different types of rights described above. [section 581]
Where Australian residents hold or were entitled to acquire attribution percentages which together are greater than 100% for a particular FIF, the total percentage is reduced to 100% and each individual taxpayer's attribution percentage is reduced proportionately. [subsection 581(4)]
Attribution percentage for interests in a foreign trust - boxes E and G
When all the income, profits or gains - referred to below as income - derived by a foreign trust during a notional accounting period consist of either or both:
- income to which beneficiaries were presently entitled
- income to which beneficiaries were not presently entitled, but which was distributed to beneficiaries during, or within two months after the end of, the notional accounting period,
then the attribution percentage is the percentage of the total income derived by the trust to which you were presently entitled or were not presently entitled but which was distributed to you during, or within two months after the end of, the notional accounting period.
If the income, profits or gains of a foreign trust are not fully distributed or allocated to beneficiaries, your attribution percentage will be equal to the greater of the percentages of your interest in or entitlement to acquire:
- the income of the trust, or
- the capital of the trust. [subsection 582(7)]
Where the total of all Australian residents' attribution percentages is greater than 100%, each individual taxpayer's attribution percentage is reduced proportionally so that the total is 100%. [subsection 582(6A)]
Last modified: 27 May 2005QC 17512