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Record keeping for a controlled foreign company

Last updated 4 December 2006

You will need to keep records of your interest in a CFC and of its financial transactions if you meet both of the following conditions:

  • you are an attributable taxpayer of a controlled CFC at the end of the company's statutory accounting period, and
  • the company has attributable income.

You must keep records of:

  • the circumstances that resulted in you becoming an attributable taxpayer for the statutory accounting period of the CFC
  • how you worked out your direct and indirect attribution interest and your attribution percentage for the CFC's statutory accounting period, and
  • how you worked out the amount you included in your assessable income.

You must keep records of your calculations even if they show that no amount is to be included in your assessable income.

Specific record keeping requirements called attribution accounts apply where an amount is included in an attributable taxpayer's assessable income due to a CFC paying a dividend to another controlled entity.

QC18000