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  • Question 25



    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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    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