Income Tax Assessment Act 1936
PART X
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ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES
Where:
(a) the eligible CFC pays an eligible finance share dividend, a widely distributed finance share dividend or a transitional finance share dividend during or after the eligible period; and
(b) if, on the assumption that the dividend were instead a payment of the interest, referred to in paragraph 327(d) or 327A(3)(b) or subsection 327B(2) , as the case requires, to which it may reasonably be regarded as equivalent, an amount (in this section called the ``interest equivalent'' ) of that interest accruing during the eligible period would be a notional allowable deduction for the eligible period;
Division 7
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Calculation of attributable income of CFC
Subdivision B
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General modifications of Australian tax law
SECTION 394
394
NOTIONAL ALLOWABLE DEDUCTION FOR ELIGIBLE FINANCE SHARE DIVIDENDS, WIDELY DISTRIBUTED FINANCE SHARE DIVIDENDS AND TRANSITIONAL FINANCE SHARE DIVIDENDS
Where:
(a) the eligible CFC pays an eligible finance share dividend, a widely distributed finance share dividend or a transitional finance share dividend during or after the eligible period; and
(b) if, on the assumption that the dividend were instead a payment of the interest, referred to in paragraph 327(d) or 327A(3)(b) or subsection 327B(2) , as the case requires, to which it may reasonably be regarded as equivalent, an amount (in this section called the ``interest equivalent'' ) of that interest accruing during the eligible period would be a notional allowable deduction for the eligible period;
then the interest equivalent is a notional allowable deduction for the eligible period.
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