A CCIV is a new type of Australian company registered and regulated by the Australian Securities & Investments Commission (ASIC). The regime began on 1 July 2022.
The CCIV framework was introduced by the Corporate Collective Investment Vehicle Framework and Other Measures Act 2022. This introduced:
- Chapter 8B into the Corporations Act 2001 (Corporations Act)
- Subdivision 195-C into the Income Tax Assessment Act 1997 (ITAA 1997).
A CCIV is:
- a type of company limited by shares that is used for funds management
- an umbrella vehicle that is made up of one or more CCIV sub-funds
- operated by a single corporate director.
A sub-fund of a CCIV is all or part of their business that is registered by ASICExternal Link.
The CCIV tax framework objective is that the general tax treatment of CCIVs and their members is aligned with the existing tax treatment of attribution managed investment trusts (AMITs) and their members.
The law does not provide an exclusive set of rules for taxing CCIVs. A deeming principle operates with the intent of subjecting a CCIV to existing tax laws for trusts, in particular the AMIT regime.
For the purposes of all tax laws, unless expressly excluded, a trust is deemed to exist between:
- a CCIV
- the business, assets and liabilities referable to a sub-fund
- the relevant class of members.
This has the effect that, for tax purposes, generally the:
- assets, liabilities and business referable to a CCIV sub-fund are treated as a separate unit trust (known as a ‘CCIV sub-fund trust’)
- CCIV is treated as the trustee of the CCIV sub-fund trust
- holders of shares in the CCIV which are referable to a particular CCIV sub-fund are treated as holding units in that sub-fund trust.
Nothing in the tax law operates to establish a CCIV sub-fund trust as being outside the boundaries of the tax system.
Where a CCIV sub-fund trust:
- meets the AMIT eligibility criteria, it is intended to be taxed as an AMIT under the attribution flow-through tax regime
- does not meet the AMIT eligibility criteria, it is intended to be taxed in accordance with general trust provisions.
It is not necessarily the case that the CCIV regime will achieve the same outcomes as trusts under the AMIT or general trust provisions.
The tax regime is focused on providing CCIVs with access to the same attribution-based flow-through tax regime that applies to AMITs.
To access the AMIT regime in an income year, CCIV sub-funds must meet the modified AMIT eligibility criteria outlined in the tax framework for that income year.
This means a CCIV sub-fund trust must satisfy all requirements for determining AMIT eligibility as specified in Divisions 275 and 276 of the ITAA 1997, subject to various modifications. Modifications include those where a CCIV and its sub-funds are not managed investment schemes under the Corporations Act.
Where a CCIV sub-fund trust meets the modified AMIT eligibility criteria, it will automatically be treated as an AMIT. In contrast, an eligible managed investment trust (MIT) has the option to either irrevocably choose to be an AMIT or remain outside the regime.
If a CCIV sub-fund trust does not meet the AMIT eligibility requirements in an income year, it is intended to be taxed as either a:
- Division 6 CCIV sub-fund trust under the general trust provisions in Division 6 of Part III of the Income Tax Assessment Act 1936 (ITAA 1936)
- Division 6C CCIV sub-fund trust (as a public trading trust) under Division 6C of Part III of the ITAA 1936 if at any time in the income year it carries on or controls (directly or indirectly) a trading business and satisfies the rules for being 'public'.
If a CCIV sub-fund trust does not meet the eligiblity criteria to be taxed as an AMIT in an income year, the lodgement requirements that apply will depend on which criteria have not been met.
How to contact us
If your CCIV sub-fund trust has failed to meet the AMIT criteria, email us at:
There is a 3-phase registration process for a CCIV and its sub-funds:
- Obtain an Australian Financial Services License (AFSL) that authorises the corporate director to operate a CCIV.
- Register CCIV and sub-funds with ASIC.
- Apply for a tax file number (TFN) (and Australian business number (ABN) if applicable) for the CCIV and its sub-funds.
A CCIV must have a corporate director that:
- is a public company
- holds an AFSL authorising it to operate the business and conduct the affairs of a CCIV.
Work out how to apply for an AFSL with ASICExternal Link and the required conditions to operate a CCIV.
A CCIV and its sub-funds must be registered by ASICExternal Link before registering with us.
After a CCIV and its sub-funds have been registered by ASIC, the CCIV structure can:
- apply for ABNs and TFNs
- register for goods and services tax (GST) online at Australian Business Register (ABR)External Link.
A CCIV and each of its sub-funds will need to register with us as separate entities. Registration details can also be changed at ABRExternal Link.
To check if a CCIV sub-fund (or CCIV) holds an ABN, search on ABN LookupExternal Link.
A CCIV should consider its circumstances to determine if TFN and ABN registration separate to the CCIV sub-fund trust registration is needed.
To apply for a TFN and an ABN, under the Which of the following are you? drop-down box:
- Select Corporate Collective Investment Vehicle.
- At the type of entity, select Company, Partnership, Trust or other organisation.
- For organisation type, select Other incorporate entity.
- Then answer the questions that follow.
CCIV sub-fund trust
To apply for a TFN and an ABN for a CCIV sub-fund trust, under the What type of organisation is the applicant? drop-down box:
- Select Corporate Collective Investment Vehicle Sub Fund.
- At the type of entity, select Company, Partnership, Trust or other organisation.
- Then answer the questions that follow.
The corporate director of a CCIV is entitled to an ABN as a public company. Find out how to apply for an ABNExternal Link. From the Organisation type drop-down box:
- Select Australian public company.
- Answer the questions that follow.
The CCIV corporate director is not eligible for or required to have a director identification number.
A CCIV, as a Corporations Act company, is entitled to have an ABN. A CCIV will generally not need to register for GST because it will not be carrying on an enterprise in its own right.
CCIV sub-fund trust
To determine if a CCIV sub-fund trust is required to be registered for GST, it needs to consider:
- if it is carrying on an enterprise
- its GST turnover.
Where more than one CCIV sub-fund trust is required to be registered for GST, each CCIV sub-fund trust will need to register separately.
The corporate director will need to consider if it is required to register for GST in its own right.
Other tax registration requirements
Entities in a CCIV structure may have other taxation obligations. For example, a sub-fund and a corporate director may need to register for pay as you go withholding.
Reporting and lodgment obligations for tax purposes generally arise at the CCIV sub-fund trust level. A CCIV sub-fund is required to lodge the following:
- income tax return, if applicable
- Annual investment income report (AIIR)
- activity statement
CCIV sub-funds must issue Attribution managed investment trust member annual (AMMA) statements if the sub-fund meets the AMIT requirements.
The CCIV is generally not required to:
- lodge an income tax return or AIIR
- issue AMMA statements or SDS to investors.
Income tax return
Attribution CCIV sub-fund lodgment requirements
Attribution CCIV sub-funds will lodge an Attribution CCIV sub-fund tax return (ACSITR). This is a bespoke income tax return that reflects the unique structure and circumstances of a CCIV sub-fund that meets the AMIT eligibility requirements.
The ACSITR shares common labels with the AMIT return and can also only be lodged electronically.
There will be differences to the lodgment requirements for the CCIV sub-fund for that year if:
- a CCIV sub-fund trust fails the AMIT eligibility criteria for an income year
- Division 6C applies.
Division 6 lodgment requirements
If a CCIV sub-fund trust fails the AMIT eligibility criteria for the income year, an ACSITR should not be lodged. The following will be required:
- trust return for the income year
- statement of distribution through the trust return
Division 6C lodgment requirements
If Division 6C applied to your circumstances at any point during the income year, an ACSITR should not be lodged.
You should lodge a Company tax return. To do this, you need to register a new TFN.
If you have changed lodgement requirements due to your circumstances and require more information, contact us.
Business activity statement (BAS)
Depending on the circumstances of the CCIV sub-fund trust or the corporate director, a BAS may be required.
The BAS will report and pay:
- PAYG instalments
- PAYG withholding tax
- other taxes.
Annual Investment Income Report (AIIR)
Generally, CCIV sub-funds must lodge an AIIR, outlining amounts attributed to investors for the income year.
From Tax Time 2022–23, all CCIV sub-funds, MITs and AMITs will be required to report using either the specific or global option.
Specific AIIR option
The Specific AIIR option requires lodging an AIIR on behalf of each:
- CCIV sub-fund
Include details of the CCIV sub-fund at the investment body section and attribution details at investor level information.
Global AIIR option
Larger preparers can use the Global AIIR option to complete a single AIIR for multiple entities.
To provide details of each CCIV sub-fund or AMIT that attributed amounts to an investor, use Interposed Entity TFN/ABN and Interposed Entity Name fields.
More information on each approach and how to complete the AIIR is available in the AIIR companion guideExternal Link. A new version will be released before Tax Time 2023.
Attribution managed investment trust member annual (AMMA) statement
CCIVs as deemed trustees of attribution CCIV sub-funds must give an AMMA statement within 3 months of the end of the income year to each person who was a member of the sub-fund during the income year.
Trustees of non-AMIT CCIV sub-funds should use the Standard Distribution Statement (SDS) for their investors. See how to complete these statements.
The CCIV tax regime uses the same attribution flow through tax regime that applies to AMITs. To access the AMIT regime, a CCIV sub-fund must meet the eligibility criteria. CCIV sub-funds can generally be considered an attribution investment vehicle for tax purposes.
Investment bodies, such as CCIV sub-funds and custodians, lodge reports with us on an annual basis, disclosing:
- amounts attributed to them
- withholding taxes collected.
Australian tax residents
Australian tax resident investors will receive AMMA statements from their CCIV sub-fund outlining their distributions for the income year. Statements include the information required for the investor's income tax return.
For individuals, myTax will pre-fill CCIV sub-fund investment income. You should always check the pre-fill amounts against your records.
Investor under an Australian tax treaty
To apply tax treaties, Australia treats the business, assets and liabilities of each sub-fund as the trust estate of separate unit trusts where the:
- CCIV is the trustee
- members of the sub-fund are the beneficiaries.
This is despite the legal form of the CCIV as a new type of company under Australian company law.
If the CCIV sub-fund trust meets the modified AMIT eligibility criteria, it is eligible for the same treatment under the treaty as if it were an AMIT.
The following example in the Explanatory Memorandum to the Corporate Collective Investment Vehicle Framework and Other Measures Bill 2021 (Example 13.1) demonstrates how treaty arrangements will apply from an Australian domestic perspective:
ADHP Investments CCIV has one sub-fund – sub-fund A, through which it derives $1 million of income in an income year. This income is comprised of $500,000 of interest, $300,000 of royalties and $200,000 of dividends.
ADHP Investments CCIV distributes $1,000, comprised of the same proportions, to a member who is a resident of a country with which Australia has double taxation agreement.
Applying the priority rule and deeming principle, for treaty purposes, the distribution is not recognised as a $1,000 dividend payment by ADHP Investments CCIV to the member. Instead, the income derived by ADHP Investments CCIV retains its character in the hands of the member, meaning that they receive $500 of interest, $300 of royalties and $200 of dividends. These amounts are subject to any applicable treaty arrangements, including the withholding rates for interest, royalties and dividends.
See more about withholding rules.
The deemed trust relationship that arises under the CCIV tax framework also applies for GST purposes.
Supplies by corporate director
The corporate director needs to consider the capacity in which it makes supplies and acquisitions. For example:
- When the corporate director makes supplies in its own capacity (as a public company), it will be liable for GST on those supplies, subject to meeting the requirements of section 9-5 of the GST Act.
- When the corporate director makes acquisitions from third parties in its capacity as corporate director, the acquisition is made by the CCIV sub-fund trusts. In this case the corporate director will not be liable for GST.
Issue of shares in a CCIV
When a CCIV issues shares referable to a sub-fund (in legal form), it is treated for tax purposes as the supply of units issued by the CCIV sub-fund trust. The CCIV sub-fund trust is treated as making the supply rather than the CCIV.
If the CCIV sub-fund trust is registered or required to be registered for GST, this supply will be treated as a financial supply of a security by the CCIV sub-fund trust. This supply is therefore an input taxed financial supply.
The supply may be GST-free if made in certain circumstances to a non-resident:
- outside the indirect tax zone
- for use outside the indirect tax zone.
Other supplies by a CCIV sub-fund trust
A CCIV sub-fund trust may make other supplies such as selling assets (for instance, real property) of the sub-fund.
GST liability from these supplies will be determined under the general GST rules as if each CCIV sub-fund trust was a separate entity.
Acquisitions and input tax credits
In a GST context, a CCIV sub-fund trust may make acquisitions of goods and services from:
- the corporate director acting in its own capacity
- other entities, via the corporate director acting in its capacity as corporate director of the CCIV for each CCIV sub-fund trust.
In either case, the CCIV sub-fund trust may be entitled to an input tax credit or reduced input tax credit.
If the corporate director makes acquisitions of goods and services for a CCIV sub-fund trust, it will not be entitled to any input tax credits.
Tax invoices for CCIV sub-fund trusts
A tax invoice must contain enough information to ascertain the recipient's identity or ABN if the total price is at least $1,000. For CCIV sub-fund trusts this means where an acquisition is for:
- a single CCIV sub-fund trust, the information in the tax invoice must determine the identity or ABN of that CCIV sub-fund trust before attributing the input tax credit
- more than one CCIV sub-fund trust, the information in the tax invoice must determine the identity or ABN of each CCIV sub-fund trust.
To implement the CCIV regime, we continue to consult with an industry working group.How to register and meet lodgment and reporting obligations for Corporate Collective Investment Vehicles (CCIVs).