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

Last updated 18 June 2019

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