• Direct attribution interest in a CFC

    Attention

    Warning:

    This information may not apply to the current year. Check the content carefully to ensure it is applicable to your circumstances.

    End of attention

    Your direct attribution interest in a CFC is the greatest of the percentages that you hold or are entitled to acquire, of the following:

    • total paid up share capital in the CFC
    • total rights to vote, or to participate in any decision making, in relation to
      • the distributions of capital or profits
      • changing of constituent documents
      • varying of share capital of the CFC
       
    • total rights to distributions of capital or profits of the CFC on winding-up
    • total rights to distributions of capital or profits of the CFC other than on winding-up.

    Test time

    Your direct attribution interest in a CFC is measured at a point in time called a test time. The test time may occur during the accounting period of a CFC.

    In some cases, it may not be possible to measure the percentage you hold of the total rights to the profits of a company or to a distribution of capital on winding-up of the company before the end of the company's accounting period.

    In these cases, your rights to capital or profits are measured at the end of the accounting period of the company. It is assumed for this purpose that the rights you held at the test time are held at the end of the company's accounting period.

    Exclusion of eligible finance shares

    In working out your direct attribution interest in a CFC, eligible finance shares in the CFC are not taken into account.

    Last modified: 05 Dec 2006QC 18000