Taxation Determination

TD 92/109A - Addendum

Income tax: foreign income: does a controlled foreign company (CFC) which conducts its business on a cyclical basis satisfy the active income test?

FOI status:

may be released

This Addendum forms part of the Determination and, to the extent that it is capable of being a 'public ruling' in terms of Part IVAAA of the Taxation Administration Act 1953, it is a public ruling for the purposes of that Part. Taxation Rulings TR 92/1 and TR 97/16 together explain when a Determination is a public ruling and how it is binding on the Commissioner.


Taxation Determination TD 92/109 is amended, with effect for statutory accounting periods of controlled foreign companies commencing after 30 June 1997, as follows:

Paragraph 1
Omit 'listed'; substitute 'broad-exemption listed'.
Omit 'unlisted'; substitute 'non-broad-exemption listed'.

Commissioner of Taxation
17 December 1997


ATO references:
NO 97/8183-8

ISSN 1038 - 8982

Related Rulings/Determinations:

TD 92/109

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