• Chapter 1: Attribution of the current year profits of a controlled foreign company (CFC)

    Attention

    Warning:

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

    End of attention

    This chapter explains the accruals tax system for residents with interests in foreign companies.

    The accruals tax system applies to Australian residents who have a substantial interest in a foreign company controlled by Australians, referred to as a CFC. The system operates to include a taxpayer's share of specified income and gains of a CFC in the taxpayer's assessable income: this is called attribution. Subject to some modifications, the income and gains of CFCs are worked out using the same tax rules that apply for residents.

    Part 1

    Are you subject to the CFC measures?

    Part 2

    Does the CFC satisfy the active business test?

    Part 3

    Working out attributable income and the amount to include in your assessable income

     

      Last modified: 28 Jun 2013QC 28180