Income Tax Assessment Act 1936
PART X
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ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES
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;
Division 3
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Control interests, attribution interests, attributable taxpayers and attribution percentages
Subdivision B
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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.
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