Question 25



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Complete by placing an 'X' in the applicable box.

This information will help us to identify if there is a risk that a transaction has occurred to which section 47A of the ITAA 1936 would apply.

When a CFC resident in an unlisted country provides, either directly or indirectly, an eligible benefit to an associated entity, section 47A can apply to deem that benefit a dividend.

Unless otherwise specified, the terms in this question have the same meaning as set out in section 47A of the ITAA 1936.

Broadly, a benefit is defined in section 47A to include the following:

  • a waiver or release of an obligation to pay or repay an amount (waiver of debts)
  • the granting of a non-arm's length loan
  • transfers of property or services for no or inadequate consideration
  • the payment of a call on an allotment of shares
  • share or unit acquisitions for non-arms length consideration.
Last modified: 09 Nov 2011QC 24292