Attributable income is the amount taxed on an accruals basis under controlled foreign company measures. Only certain types of income are included in attributable income.
There are two key factors that indicate whether an item of income will be attributable income under the controlled foreign company rules. These are:
- if the income has been taxed overseas in a way that is not comparable with how it would have been taxed if earned in Australia
- if the income is 'tainted income', which includes passive income, tainted sales income and tainted services income.
If the income satisfies both these requirements it will be attributed under the controlled foreign company rules.