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Part 1 - Record keeping for attributable taxpayers

Last updated 4 December 2006

Who needs to keep records?

You must keep records (as set out below) if you are an attributable taxpayer of:

  • a controlled foreign company (CFC), or
  • a non-resident trust estate.

An attributable taxpayer is a person who:

  • alone, or together with associates, has an interest in a CFC or a controlled foreign trust of at least 10% or
  • is a transferor of a non-resident trust, or
  • is one of the actual controllers of the CFC with an interest of at least 1%.

QC18000