Trustee liabilities and additional information

Trustee liabilities of the CCIV sub-fund

The trustee of a CCIV sub-fund trust is liable to pay income tax on certain amounts.

It is important you show the taxable amount at each item. That is, the amount on which you're liable to pay tax. Don't enter the amount of tax to be paid. We will apply the relevant tax rate to the amount entered.

Where the trustee of a CCIV sub-fund trust is liable to pay tax, the amount of tax payable by the trustee will be set out in a notice of assessment issued to the trustee.

If the trustee is liable to pay tax under sections 276-405, 276-410 or 276-415 of the ITAA 1997, the Commissioner may fully or partially remit the tax, under section 276-430, if satisfied that there is no detriment to the revenue.

For example, remission of tax may be considered to the extent that a shortfall of an income character or an over of a non-refundable tax-offset character would have been attributed to tax-exempt entities.

Submit any requests for the exercise of the Commissioner's discretion to remit income tax under section 276-430 via the Online services for business Secure mail or the Online services for agents Client communication and include the reasons for your request.

Is any tax payable by the trustee?

Under the CCIV regime, the members, not the trustee, are generally taxed on amounts of an assessable income character attributed to them and entitled to credits from attributed tax offset amounts.

However, there are situations where tax may also be payable by the trustee, typically in respect of amounts of an income character that have been under-attributed to members, or amounts of a tax offset character that have been over-attributed to members.

If the trustee is liable to pay tax in respect of any trustee liabilities, answer Yes at this question even if payments have been made in advance.

Trust component deficit of character relating to tax offset

You must adjust trust components for unders, overs and rounding adjustments under sections 276-305, 276-310 and 276-315 of the ITAA 1997. If the net adjustment would result in a trust component being a negative amount, the trust component is reduced to zero and there will be a trust component deficit equal to the remaining adjustment amount under section 276-320.

If the deficit relates to a tax offset (other than foreign income tax offsets), the trustee is required to pay tax on the deficit under section 276-340. This recognises that the overall amount of that offset previously attributed to members, is more than the tax offset of the AMIT.

Write at this item the total of any amounts you're liable to pay tax on under section 276-340.

Shortfall in determined member components of character relating to assessable income

At this item, complete the label Shortfall in determined member components of character relating to assessable income.

Under section 276-405 of the ITAA 1997, the trustee of a CCIV sub-fund trust is liable to pay tax on the shortfall between a determined member component of an assessable income character and the member component of that character.

The determined member component is the amount the CCIV sub-fund trust advised its member in the member statement (AMMA statement). The member's member component is the amount attributed to the member fairly and reasonably in accordance with the constituent documents of the CCIV sub-fund trust and without regard to the member's tax characteristics.

Write at this item the total of any amounts you're liable to pay tax on under section 276-405.

Excess in determined member components of character relating to tax offset

At this item, complete the label Excess in determined member components of character relating to tax offset.

Under section 276-410 of the ITAA 1997, the trustee of a CCIV sub-fund trust is liable to pay tax on any excess of a determined member component of a tax offset character over the member component of that character.

Write at this item the total of any amounts you're liable to pay tax on under section 276-410.

Determined trust component amounts that are not reflected in Member Components

At this item, complete the label Determined trust component amounts that are not reflected in Member Components.

Under section 276-415 of the ITAA 1997 the trustee of a CCIV sub-fund trust is liable to pay tax on the shortfall between total determined member components of a particular assessable income, exempt income or non-assessable non-exempt income character and the determined trust component of that character. Broadly, the shortfall represents income amounts of the CCIV sub-fund trust that haven't been effectively attributed to members.

Where the shortfall relates to the character of a discount capital gain, you must double the shortfall amount and include it at this item. This represents the amount that would otherwise have been recognised by members under section 276-85.

The shortfall is reduced by the amount of any rounding adjustment deficit and any amount that is reflected in a shortfall in determined member component of character relating to assessable income. The first reduction is to ensure that trustees aren't taxed on relatively small amounts that inevitably arise from rounding variances between trust components and total member components. The second reduction is to prevent double tax of amounts already assessable to the trustee under section 276-405.

Write at this item the total of any amounts you're liable to pay tax on under section 276-415.

Other trustee liabilities

The trustee of a CCIV sub-fund trust is also liable to pay tax in the following situations:

• under section 276-105 on amounts of each foreign resident member's determined member components, where the AMIT isn't a withholding MIT (see Statement of attribution for non-withholding attribution CCIV sub-fund)
• pursuant to section 276-420 on under amounts of a character relating to assessable income not properly carried forward
• pursuant to section 276-425 on over amounts of a character relating to tax offset not properly carried forward.

For any trustee liability pursuant to sections 276-420 or 276-425, these assessments are typically initiated by the Commissioner when there is disagreement with the trustee concerning the amount of the income under-recognised or offset over-recognised in an income year. See Law companion ruling LCR 2015/9 Attribution Managed Investment Trusts: trustee shortfall taxation – section 276-420.

In some situations, trustees may initiate an assessment under these provisions. If this applies to you, you must notify us in writing under section 275-605 on amounts of non-arm’s length income of a MIT that you have identified. The Commissioner will then make a determination of non-arms' length income and initiate assessments as appropriate. See LCR 2015/15 Managed Investment Trusts: the non-arm's length income rule in sections 275-605, 275-610 and 275-615 of the Income Tax Assessment Act 1997.

If the trustee is liable to pay tax under sections 276-420 or 276-425, the Commissioner may fully or partially remit the tax, under section 276-430, if satisfied that there is no detriment to the revenue.

For example, remission of tax may be considered to the extent that a shortfall of an income character or an over of a non-refundable tax-offset character would have been attributed to tax-exempt entities.

Submit any requests for the exercise of the Commissioner's discretion to remit income tax under section 276-430 through the Online services for business Secure mail and include the reasons for your request. Alternatively, your registered tax agent can send a request through Online services for agents Client communication.

Additional information

Follow the steps to complete this section of the tax return.

Final tax return

Answer Yes or No as appropriate.

If you don't expect to lodge further CCIV sub-fund tax returns, enter 'Final trust tax return' in the Additional Information field and explain:

• the reason that further tax returns won't be lodged
• the manner of disposal of any assets of the CCIV sub-fund trust, if not disclosed elsewhere on the tax return.

Number of members in the CCIV sub-fund at the end of the income year

Write the number of members of the CCIV with interests referable to the CCIV sub-fund at the end of the financial year.

Write only the number of shareholders shown in the CCIV's membership records. A single entity (such as a custodian) should identify each separate member investment. Specifically, the CCIV will need to identify the membership interests held:

• in more than one CCIV sub-fund of the CCIV
• on behalf of more than one member.

Significant global entity

Complete this item if the entity was a significant global entity (SGE) for the income year. In determining whether you're a significant global entity, consider your circumstances as a CCIV sub-fund. Don't complete this question on an aggregated CCIV basis.

An entity is an SGE if it is either:

• a global parent entity with an annual global income of A$1 billion or more
• a member of a group of entities consolidated for accounting purposes, and one of the other group members is a global parent entity with an annual global income of A$1 billion or more
• a member of a notional listed company group, and one of the other group members is a global parent entity with an annual global income of A$1 billion or more.

A notional listed company group is a group of entities that would be required to be consolidated for accounting purposes as a single group, on the assumption that an entity of the group were a listed company. You should disregard any exceptions to consolidation in the accounting principles or commercially accepted principles related to accounting (CAAP) when determining whether a group of entities would be required to be consolidated for accounting purposes. Also disregard any rule in those principles providing that entities aren't required to be consolidated as a single group because the effect of consolidating would be immaterial based on the size of the entities, or for other reasons.

An entity is also a SGE if it is a global parent entity, or a member of an actual or notional accounting consolidated group which includes a global parent entity, and the global parent entity has been given a notice by the Commissioner determining that its annual global income would have been A$1 billion or more for the period had global financial statements been prepared. If you're a SGE, you also need to consider whether you're a country-by-country (CBC) reporting entity. CBC reporting entities must complete the country-by-country (CBC) reporting entity label and may have additional reporting obligations.

Country-by-country (CBC) reporting entity

Complete this item if the entity was a CBC reporting entity for the income year.

An entity is a CBC reporting entity if it is either:

• a CBC reporting parent
• a member of a CBC reporting group, and one of the other group members is a CBC reporting parent.

A CBC reporting parent is an entity with an annual global income of A$1 billion or more that isn't an individual, and, if it is a member of a CBC reporting group, isn't controlled by any other entity within the CBC reporting group according to the applicable accounting principles or CAAP.

A CBC reporting group refers to either a group that is consolidated for accounting purposes as a single group or a notional listed company group. A notional listed company group is a group of entities that would be required to be consolidated for accounting purposes as a single group, on the assumption that an entity of the group were a listed company.

Unlike the SGE definition, certain exceptions to consolidation in the accounting principles or CAAP are taken into account in working out the membership of the CBC reporting group. Where such exceptions apply, the CBC reporting group may have fewer members than the equivalent SGE group. Note that entities that aren't required to be considered under the accounting principles or CAAP based on materiality may also be members of the CBC reporting group.

If an entity was a CBC reporting entity for the whole or part of the preceding income year, it may have CBC reporting obligations in relation to the current income year.

For more information about the definition of a CBC reporting entity and what it means to be a CBC reporting entity, see Country-by-country reporting.

Industry code

Write the appropriate industry code for the CCIV sub-fund trust’s main business. Use the Business industry code tool to search by the business activity description to find the correct code.

The industry code is made up of 5 digits. For example, if the industry is ‘commercial non-residential property investment’, the code to show on the tax return is 67120.

An incorrect code may result in:

• you not receiving a necessary service or material
• the ATO incorrectly targeting audits.

The industry code provided is also used to publish industry benchmarks in taxation statistics.

The industry coding regime we use is a modified version of the Australian and New Zealand Standard Industrial Classification (ANZSIC)External Link, produced jointly by the Australian Bureau of Statistics (ABS) and Statistics New Zealand.

MIT type

Choose a MIT type from the table below. If the MIT is more than one MIT type, answer as follows:

• if MIT type code B is one of these, answer code B
• if not code B, but code A with any other code, answer code A
• if not codes A or B, but is code C with any other code, answer code C
• if not codes A, B or C, but is codes E, H or P, answer code H.

Table: MIT type and codes

MIT type	MIT code
Affordable housing MIT A MIT is an affordable housing MIT if it holds interests in residential accommodation available at below market rental prices, under the Affordable housing scheme. If the MIT is more than one MIT type listed in this table, see the rules before the table.	A
Build to rent (BTR) MIT A MIT is a BTR MIT if it owns one or more active build to rent developments. An active build to rent development is an Australian build to rent development that meets the following the eligibility criteria for the build to rent development tax incentives the owner (or a former owner) has notified the Commissioner in the approved form of their choice for the development to be an active build to rent development has during the required minimum period for that development continually met the ongoing eligibility conditions, or if not, the Commissioner has exercised their discretion to reinstate the development's access to the incentives where certain criteria are failed. For more information, see Build to rent development tax incentives. Even if the MIT is also another MIT type listed in this table, answer code B at MIT type.	B
Clean building MIT A MIT is a clean building MIT if it both: holds one or more clean buildings, including the land on which the buildings are situated doesn't derive assessable income from any taxable Australian property, other than from the clean buildings or assets that are reasonably incidental to those buildings. If the MIT is more than one MIT type listed in this table, see the rules before the table.	C
Equity MIT A MIT is an equity MIT if it invests in equity assets only including one or more of: shares in ASX listed companies shares listed on a foreign exchange units in trusts interests in bonds and debentures. If the MIT is more than one MIT type listed in this table, see the rules before the table.	E
Hybrid MIT A MIT is a hybrid MIT if it invests in both: equity assets (including shares, units, bonds, and debentures) property or interests in property. If the MIT isn't an MIT type A, B or C, but E, H and P, answer code H.	H
Property MIT A MIT is a property MIT if it invests in only one or more of: property an interest in property. If the MIT is more than one MIT type listed in this table, see the rules before the table.	P

Description of main business activity

Select the option from the drop-down menu that best describes the investment mandate of the CCIV sub-fund for the income year.

If you can't identify an appropriate selection from the options that are available, select the Other category and note the reason for this choice in the Additional Information box.

Electronic funds transfer (EFT)

We need your financial institution details to pay any refund owing to the CCIV sub-fund trust, even if you have provided them to us before.

Complete the:

• bank state branch (BSB) number – this 6 digit number identifies the financial institution (don't include spaces or hyphens)
• account number – this number shouldn't have more than 9 characters (don't include spaces)
• account name – your account name should be as shown on your bank account records. It should include spaces between each word and between initials. If your account name exceeds 32 characters, provide the first 32 characters only.

Reportable tax position

You must complete this section (and, if required, the Reportable tax position schedule 2026) based on your circumstances as a CCIV sub-fund.

CCIV sub-fund trusts must lodge a Reportable tax position schedule 2026 if they meet the Reportable tax position schedule lodgment criteria.

This question asks:

Are you required to lodge a reportable tax position schedule?

Indicate Yes or No in the space provided, as appropriate to your circumstances.

If you answer Yes, you must complete a Reportable tax position schedule 2026.

For more information on the Reportable tax position schedule lodgment criteria see Who needs to complete the schedule? in the Reportable tax position schedule and instructions 2026.

Continue to: Transactions, thin capitalisation and financial information

Return to: Instructions to complete the attribution CCIV sub-fund tax return 2026