Income Tax Assessment Act 1936

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

Division 11 - Keeping of records  

SECTION 462A   462A   KEEPING OF RECORDS - SECTION 457  


Subject to this Division, where:


(a) subsection 457(1) applies to a change of residence of a CFC; and


(b) at the residence-change time referred to in that subsection, a person is an attributable taxpayer in relation to the CFC;

the person must keep records (in Australia or elsewhere) containing particulars of:


(c) the acts, transactions and other circumstances that resulted in the person being an attributable taxpayer in relation to the CFC at that time; and


(d) the basis of the calculation of:


(i) the direct attribution interest; and

(ii) the aggregate of the indirect attribution interests;
in the CFC held by the person at that time; and


(e) the basis of the calculation of the attribution percentage of the person in relation to the CFC at that time; and


(f) the basis of the calculation of the amount (including a nil amount) included in the assessable income of the person under section 457 in relation to the change of residence concerned.


 

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