Income Tax Assessment Act 1936

PART X - ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES  

Division 3 - Control interests, attribution interests, attributable taxpayers and attribution percentages  

Subdivision B - Attribution interests  

SECTION 359  

359   ATTRIBUTION TRACING INTEREST IN A CFP  

An entity that is a partner in a CFP holds an attribution tracing interest in the CFP at a particular time equal to the percentage that the entity holds, or is entitled to acquire, at that time of:

(a) the total interests in the profits of the CFP; or

(b) the total interests in the CFP property;

or, if those percentages differ, the greater of those percentages.