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  • Foreign income

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    Warning:

    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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    22 Attributed foreign income

    Find out more

    For more information on calculating the amounts shown at M, U and X, see the Foreign income return form guide 2013–14 (NAT 1840).

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    If the partnership was a subsidiary member of a consolidated group or MEC group for the entire income year, the International dealings schedule 2014 is not required.

    Where the partnership is a member of a consolidated group or MEC group for the whole income year and derived foreign income, the responsibility for preparing the schedule will rest on the head company of the group.

    Where a return is required because the partnership had a period in the income year when it was not a member of a consolidated group or MEC group (a non-membership period), the partnership should complete an International dealings schedule where it has derived foreign income attributable to any non-membership period.

    Did you have overseas branch operations or a direct or indirect interest in a foreign trust, foreign company, controlled foreign entity or transferor trust?

    Direct or indirect interests in a controlled foreign company or a foreign trust are taken to have the same meaning as set out in Division 3External Link of Part X of the ITAA 1936.

    A partnership has an interest in a transferor trust if the partnership has ever made, or caused to be made, a transfer of property or services to a non-resident trust. Transfer of property and services is defined in section 102AABExternal Link of the ITAA 1936.

    Sections 102AAJExternal Linkand 102AAKExternal Link of the ITAA 1936 provide guidance on whether there was a transfer, or a deemed transfer, of property or services to a non-resident trust.

    Yes Print X in the Yes box at S and complete an International dealings schedule 2014.

    No Print X in the No box at S.

    Find out more

    For more information, see the International dealings schedule instructions 2014.

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    Listed country

    Show at M the amount of gross attributed foreign income from controlled foreign entities and transferor trusts of listed countries. Listed countries are set out in Part 1 of Schedule 10 to the Income Tax Regulations 1936 (ITR 1936).

    Attributed foreign income is the income attributed to the taxpayer from controlled foreign entities, calculated in accordance with Division 7 of Part X of the ITAA 1936, and includes an amount grossed-up under section 392External Link of the ITAA 1936, to the extent of any foreign taxes paid.

    Show at M the amount of income attributed from a transferor trust that is a listed country trust estate, calculated in accordance with Subdivision D of Division 6AAA of the ITAA 1936.

    A listed country trust estate is defined in section 102AAEExternal Link of the ITAA 1936.

    Section 404 country

    Show at U the amount of attributed foreign income from controlled foreign entities in section 404 countries. Section 404 countries are listed in Part 2 of Schedule 10 to the ITR 1936.

    Also show at U the amount of income attributed from a transferor trust if the entire income and profits of the trust are subject to tax in a section 404 country. Do not include the amount if it is shown at M.

    Unlisted country

    Show at X the amount of attributed foreign income from controlled foreign entities in unlisted countries. Unlisted countries are countries that are not listed in Schedule 10 to the ITR 1936.

    Show at X the amount of income attributed from a transferor trust if the amount has not been shown at M or U.

    Last modified: 12 Feb 2019QC 40273