This part explains how to work out the attributable income of a CFC. Your share of the attributable income is included in your assessable income.
Even if the CFC passes the active income test, you will still need to read on. Passing the test will eliminate many, but not all, types of attributed income and gains.
General assumptions for working out the attributable income of a CFC |
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General modifications to the law |
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Modifications to the treatment of capital gains and capital losses |
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Quarantining of losses |
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Working out the net income of a partnership |
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Trust amounts |
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Reduction of attributable income because of interim dividends |
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Relief from double accruals taxation |
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How much is included in assessable income |
Section 1: General assumptions for working out the attributable income of a CFC
Attributable income is included directly in your assessable income. It is not necessary to aggregate amounts of attributable income as you trace through a chain of CFCs.
Example 16: Attribution directly to taxpayer
Assume you wholly own a foreign company which, in turn, wholly owns another foreign company. Also assume that the first company has $300,000 attributable income and the second company has $200,000 attributable income.
End of exampleYou include an amount in your assessable income as follows:
Like this
Not like this
Do include $300,000 from the first company and $200,000 from the second in your income.
Do not include $200,000 from the second company in the income of the first company, and $500,000 income from the first company in your own income.