Income Tax Assessment Act 1936
PART X
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ATTRIBUTION OF INCOME IN RESPECT OF CONTROLLED FOREIGN COMPANIES
In determining whether expenditure incurred by the eligible CFC during the eligible period for the purpose of gaining or producing income or profits in a later statutory accounting period is a notional allowable deduction under a particular provision, it is to be assumed that:
(a) there will be a requirement under this Division to calculate the attributable income of the eligible CFC for that later statutory accounting period; and
(b) for that purpose, the eligible CFC will always be a resident of the listed country or unlisted country, as the case may be.
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 395
395
EXPENDITURE INCURRED TO PRODUCE INCOME OR PROFITS IN LATER STATUTORY ACCOUNTING PERIODS
In determining whether expenditure incurred by the eligible CFC during the eligible period for the purpose of gaining or producing income or profits in a later statutory accounting period is a notional allowable deduction under a particular provision, it is to be assumed that:
(a) there will be a requirement under this Division to calculate the attributable income of the eligible CFC for that later statutory accounting period; and
(b) for that purpose, the eligible CFC will always be a resident of the listed country or unlisted country, as the case may be.
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