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

    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 income test?

    Part 3

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

      Last modified: 09 Sep 2021QC 66597